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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IBBI has mandated that IPs must include a dedicated section in Information Memorandums detailing carry forward losses under the Income Tax Act, 1961. This enhanced disclosure requirement follows an amendment to Regulation 36 of CIRP Regulations and observations that current disclosures lack robustness. IPs must now specifically detail: quantum of available carry forward losses, breakdown under specific heads per tax law, applicable time limits for utilization, and explicit mention if no such losses exist. This framework aims to provide resolution applicants with comprehensive understanding of the corporate debtor's financial position to develop more informed resolution plans.
IBBI has mandated that IPs must include a dedicated section in Information Memorandums detailing carry forward losses under the Income Tax Act, 1961. This enhanced disclosure requirement follows an amendment to Regulation 36 of CIRP Regulations and observations that current disclosures lack robustness. IPs must now specifically detail: quantum of available carry forward losses, breakdown under specific heads per tax law, applicable time limits for utilization, and explicit mention if no such losses exist. This framework aims to provide resolution applicants with comprehensive understanding of the corporate debtor's financial position to develop more informed resolution plans.
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