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 circular modifies certain requirements related to Offshore Derivative Instruments (ODIs) and Foreign Portfolio Investors (FPIs) with segregated portfolios. Key changes include: FPIs to issue ODIs only through a separate dedicated registration with no proprietary investments, except for ODIs with government securities as underlying. ODIs cannot have derivatives as underlying and must be fully hedged with the same securities on a one-to-one basis. Certain ODI subscribers exceeding specified thresholds in equity ODI positions or Indian market exposure must provide additional disclosures on ownership and control structure. FPIs with segregated portfolios to comply with disclosure requirements individually for each segregated portfolio. Transitory provisions allow phasing out of existing non-compliant positions over one year. The circular aims to address regulatory arbitrage and promote market development and regulation.
The circular modifies certain requirements related to Offshore Derivative Instruments (ODIs) and Foreign Portfolio Investors (FPIs) with segregated portfolios. Key changes include: FPIs to issue ODIs only through a separate dedicated registration with no proprietary investments, except for ODIs with government securities as underlying. ODIs cannot have derivatives as underlying and must be fully hedged with the same securities on a one-to-one basis. Certain ODI subscribers exceeding specified thresholds in equity ODI positions or Indian market exposure must provide additional disclosures on ownership and control structure. FPIs with segregated portfolios to comply with disclosure requirements individually for each segregated portfolio. Transitory provisions allow phasing out of existing non-compliant positions over one year. The circular aims to address regulatory arbitrage and promote market development and regulation.
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