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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Regulator permits Category I and II funds to offer co-investment via separate co-investment schemes (CIVs) within the fund framework, alongside existing portfolio-manager routes. CIVs must use separate bank/demat accounts and ring-fence assets; managers must file a shelf placement memorandum detailing terms and governance. An investor's co-investment across CIVs in an investee is capped at three times their contribution via the affiliated fund, except for multilateral/bilateral development financiers, state industrial development corporations, and government-owned/controlled entities (including central banks and sovereign wealth funds). CIVs cannot leverage or borrow; investors hold pro rata rights (subject to carried interest to sponsor/manager); costs are shared pro rata. Implementation standards must be adopted and compliance reported; immediate effect.
Regulator permits Category I and II funds to offer co-investment via separate co-investment schemes (CIVs) within the fund framework, alongside existing portfolio-manager routes. CIVs must use separate bank/demat accounts and ring-fence assets; managers must file a shelf placement memorandum detailing terms and governance. An investor's co-investment across CIVs in an investee is capped at three times their contribution via the affiliated fund, except for multilateral/bilateral development financiers, state industrial development corporations, and government-owned/controlled entities (including central banks and sovereign wealth funds). CIVs cannot leverage or borrow; investors hold pro rata rights (subject to carried interest to sponsor/manager); costs are shared pro rata. Implementation standards must be adopted and compliance reported; immediate effect.
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