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 transfer of portfolio management services (PMS) subject to prior approval: intra-group transfers may be of select investment approaches or the entire PMS (if entire business transferred, transferor must surrender registration within 45 working days); transfers between unrelated portfolio managers require a joint application, mandate transfer of the entire PMS, and obligate the transferee to assume all acts, deeds, liabilities and pending litigation via an undertaking. The transfer must be completed within two months of approval; until completion the transferor remains manager but cannot onboard new clients and must surrender registration upon handover. The circular is effective immediately and prescribes specified undertakings and documentary enclosures.
Regulator permits transfer of portfolio management services (PMS) subject to prior approval: intra-group transfers may be of select investment approaches or the entire PMS (if entire business transferred, transferor must surrender registration within 45 working days); transfers between unrelated portfolio managers require a joint application, mandate transfer of the entire PMS, and obligate the transferee to assume all acts, deeds, liabilities and pending litigation via an undertaking. The transfer must be completed within two months of approval; until completion the transferor remains manager but cannot onboard new clients and must surrender registration upon handover. The circular is effective immediately and prescribes specified undertakings and documentary enclosures.
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