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 regarding Infrastructure Debt Fund (IDF) guidelines under section 10(47). IDFs must operate as NBFCs under RBI regulations, investing exclusively in post-operational infrastructure projects with minimum one-year commercial operations or toll-operate-transfer projects. Funding mechanisms include rupee/foreign currency bonds, zero coupon bonds per Rule 8B, and external commercial borrowings with minimum 5-year tenor. ECBs cannot be sourced from foreign branches of Indian banks. Investment restrictions apply where specified shareholders (holding >=30% voting power) or associated enterprises have substantial interests. The amendment introduces stricter operational parameters and clarifies funding mechanisms while maintaining regulatory oversight by RBI and alignment with FEMA regulations.
CBDT amended Income-tax Rules 1962 regarding Infrastructure Debt Fund (IDF) guidelines under section 10(47). IDFs must operate as NBFCs under RBI regulations, investing exclusively in post-operational infrastructure projects with minimum one-year commercial operations or toll-operate-transfer projects. Funding mechanisms include rupee/foreign currency bonds, zero coupon bonds per Rule 8B, and external commercial borrowings with minimum 5-year tenor. ECBs cannot be sourced from foreign branches of Indian banks. Investment restrictions apply where specified shareholders (holding >=30% voting power) or associated enterprises have substantial interests. The amendment introduces stricter operational parameters and clarifies funding mechanisms while maintaining regulatory oversight by RBI and alignment with FEMA regulations.
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