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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CBDT amended Income Tax Rules 1962 through Second Amendment Rules 2025, introducing key changes for International Financial Services Centres. New provisions establish conditions for Venture Capital Funds under section 10(23FB), requiring them to operate as Category I Alternative Investment Funds. Rule 21ACA specifies permissible activities for Finance Companies in IFSCs, including lending, factoring, and treasury operations. Additional amendments to Rule 21AIA introduce strict requirements for retail schemes, mandating minimum investor diversification and investment limits. Exchange Traded Funds must be listed on recognized exchanges and comply with IFSCA regulations. These amendments enhance regulatory framework for fund management and financial operations in IFSCs, effective upon official gazette publication.
CBDT amended Income Tax Rules 1962 through Second Amendment Rules 2025, introducing key changes for International Financial Services Centres. New provisions establish conditions for Venture Capital Funds under section 10(23FB), requiring them to operate as Category I Alternative Investment Funds. Rule 21ACA specifies permissible activities for Finance Companies in IFSCs, including lending, factoring, and treasury operations. Additional amendments to Rule 21AIA introduce strict requirements for retail schemes, mandating minimum investor diversification and investment limits. Exchange Traded Funds must be listed on recognized exchanges and comply with IFSCA regulations. These amendments enhance regulatory framework for fund management and financial operations in IFSCs, effective upon official gazette publication.
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