Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
The RBI circular dated May 21, 2024, addresses the issuance of partly paid units to non-residents by investment vehicles as per the Foreign Exchange Management (Non-debt Instruments) Rules, 2019. The rules were amended in 2024 to allow such issuances. Alternative Investment Funds that issued partly paid units to non-residents before the amendment can regularize the same through compounding under the Foreign Exchange Management Act, 1999. AD Category-I banks must ensure necessary administrative actions, reporting through FIRMS Portal, and issue conditional acknowledgments before seeking compounding from the RBI. The circular is issued u/s 10(4) and 11(1) of the Foreign Exchange Management Act, 1999, and does not affect compliance with other laws.
The RBI circular dated May 21, 2024, addresses the issuance of partly paid units to non-residents by investment vehicles as per the Foreign Exchange Management (Non-debt Instruments) Rules, 2019. The rules were amended in 2024 to allow such issuances. Alternative Investment Funds that issued partly paid units to non-residents before the amendment can regularize the same through compounding under the Foreign Exchange Management Act, 1999. AD Category-I banks must ensure necessary administrative actions, reporting through FIRMS Portal, and issue conditional acknowledgments before seeking compounding from the RBI. The circular is issued u/s 10(4) and 11(1) of the Foreign Exchange Management Act, 1999, and does not affect compliance with other laws.
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