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 GoI amended SEZ Rules, 2025, introducing significant modifications to semiconductor and electronic component zone regulations. Key amendments include: (1) mandating minimum 10-hectare contiguous land for semiconductor manufacturing zones, (2) enabling Board discretion to relax encumbrance-free area requirements for government-mortgaged lands, (3) providing flexible export/transfer options for finished goods including domestic tariff area supply, and (4) modifying net foreign exchange calculations for semiconductor manufacturing services. The amendments aim to streamline SEZ establishment procedures, facilitate semiconductor ecosystem development, and provide operational flexibility for zone developers and units.
The GoI amended SEZ Rules, 2025, introducing significant modifications to semiconductor and electronic component zone regulations. Key amendments include: (1) mandating minimum 10-hectare contiguous land for semiconductor manufacturing zones, (2) enabling Board discretion to relax encumbrance-free area requirements for government-mortgaged lands, (3) providing flexible export/transfer options for finished goods including domestic tariff area supply, and (4) modifying net foreign exchange calculations for semiconductor manufacturing services. The amendments aim to streamline SEZ establishment procedures, facilitate semiconductor ecosystem development, and provide operational flexibility for zone developers and units.
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