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 clarifies conditions under amended Regulation 9C of the SEBI (Debenture Trustees) Regulations, 1993 for debenture trustees undertaking activities outside SEBI's purview. Such activities must be fee-based, non-fund based, financial-services related, and carried out on an arm's length basis through ring-fenced Separate Business Units with Chinese Walls, distinct staff, records, grievance mechanisms, and segregated marketing. Debenture trustees must disclose non-SEBI-regulated activities, absence of SEBI investor protection, and, where applicable, identify the relevant financial sector regulator, obtaining stakeholder acknowledgments. Existing arrangements require retrospective disclosures and confirmations within six months and half-yearly compliance reporting. RBI-regulated entities must conduct debenture trustee activities only through SBUs.
The circular clarifies conditions under amended Regulation 9C of the SEBI (Debenture Trustees) Regulations, 1993 for debenture trustees undertaking activities outside SEBI's purview. Such activities must be fee-based, non-fund based, financial-services related, and carried out on an arm's length basis through ring-fenced Separate Business Units with Chinese Walls, distinct staff, records, grievance mechanisms, and segregated marketing. Debenture trustees must disclose non-SEBI-regulated activities, absence of SEBI investor protection, and, where applicable, identify the relevant financial sector regulator, obtaining stakeholder acknowledgments. Existing arrangements require retrospective disclosures and confirmations within six months and half-yearly compliance reporting. RBI-regulated entities must conduct debenture trustee activities only through SBUs.
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