Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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The definition of "Specified Mutual Fund" u/s 50AA is proposed to be amended to provide clarity regarding the proportion of investment in debt and money market instruments, and to clarify the investment requirements for Fund-of-Funds (FoFs). A specified mutual fund shall mean a mutual fund that invests more than 65% of its total proceeds in debt and money market instruments, or a fund that invests 65% or more of its total proceeds in units of such a fund. The amendment under clause (ii) of the Explanation of section 50AA is proposed to be effective from April 1, 2026, and applicable from the assessment year 2026-27 onwards.
The definition of "Specified Mutual Fund" u/s 50AA is proposed to be amended to provide clarity regarding the proportion of investment in debt and money market instruments, and to clarify the investment requirements for Fund-of-Funds (FoFs). A specified mutual fund shall mean a mutual fund that invests more than 65% of its total proceeds in debt and money market instruments, or a fund that invests 65% or more of its total proceeds in units of such a fund. The amendment under clause (ii) of the Explanation of section 50AA is proposed to be effective from April 1, 2026, and applicable from the assessment year 2026-27 onwards.
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