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 amendment permits debenture trustees to undertake other financial-sector or fee-based non-fund activities on an arm's-length basis through separate business units, subject to conditions and specified regulator guidelines; trustees also must ring-fence required net worth and, if regulated by the central bank, operate debenture-trustee functions via a separate unit, with a six-month transition window for existing registrants. Trust deed acceptance must follow section 71/Format SH.12 timelines, allowing deviations only with a key summary and rationale in issuer disclosures. Trustees gain express inspection and information-call powers and may use a Recovery Expense Fund with debenture-holder consent.
The amendment permits debenture trustees to undertake other financial-sector or fee-based non-fund activities on an arm's-length basis through separate business units, subject to conditions and specified regulator guidelines; trustees also must ring-fence required net worth and, if regulated by the central bank, operate debenture-trustee functions via a separate unit, with a six-month transition window for existing registrants. Trust deed acceptance must follow section 71/Format SH.12 timelines, allowing deviations only with a key summary and rationale in issuer disclosures. Trustees gain express inspection and information-call powers and may use a Recovery Expense Fund with debenture-holder consent.
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