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 circular modifies Chapter IV of the Master Circular for Debenture Trustees to clarify the creation and use of the Recovery Expense Fund (REF) for enforcement and legal proceedings upon default in listed debt securities. It specifies that debenture trustees, including a defined Lead Debenture Trustee, may be reimbursed from REF for activities such as obtaining consents, conducting voting and meetings, filing court applications, legal fees, and asset recovery services. Prior debenture holder approval is not required for uses expressly listed; other uses need prior consent. The designated stock exchange must verify expenses, release funds within five working days, and remaining Chapter IV provisions remain unchanged, effective immediately.
The circular modifies Chapter IV of the Master Circular for Debenture Trustees to clarify the creation and use of the Recovery Expense Fund (REF) for enforcement and legal proceedings upon default in listed debt securities. It specifies that debenture trustees, including a defined Lead Debenture Trustee, may be reimbursed from REF for activities such as obtaining consents, conducting voting and meetings, filing court applications, legal fees, and asset recovery services. Prior debenture holder approval is not required for uses expressly listed; other uses need prior consent. The designated stock exchange must verify expenses, release funds within five working days, and remaining Chapter IV provisions remain unchanged, effective immediately.
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