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 amendments revise the InvIT regulations by narrowing the definition of "public," excluding sponsors, sponsor group, investment manager and project manager while treating specified persons who are QIBs as public; defer several fixed quarterly filing deadlines to timelines "as may be specified by the Board"; require simultaneous submission of certain valuation reports to trustees and stock exchanges and align annual/half-year valuations with financial results; mandate quarterly valuations if consolidated borrowings exceed 49% with specified submission rules; lower minimum private placement investor threshold to INR 25 lakh and remove a prior INR 25 crore exemption; permit holdco cash-flow netting with disclosure; and add enhanced quarterly reporting for high-leverage InvITs.
The amendments revise the InvIT regulations by narrowing the definition of "public," excluding sponsors, sponsor group, investment manager and project manager while treating specified persons who are QIBs as public; defer several fixed quarterly filing deadlines to timelines "as may be specified by the Board"; require simultaneous submission of certain valuation reports to trustees and stock exchanges and align annual/half-year valuations with financial results; mandate quarterly valuations if consolidated borrowings exceed 49% with specified submission rules; lower minimum private placement investor threshold to INR 25 lakh and remove a prior INR 25 crore exemption; permit holdco cash-flow netting with disclosure; and add enhanced quarterly reporting for high-leverage InvITs.
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