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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Prescribes an eligibility criterion under the AIF Regulations requiring the Compliance Officer of the Manager of an AIF to obtain NISM Series-III-C: Securities Intermediaries Compliance (Fund) certification by passing the specified examination, with managers required from 1 January 2027 to appoint or retain only certified persons as Compliance Officers, thereby rendering uncertified persons ineligible to be appointed or to continue in that role from that date. Requires the trustee/sponsor/manager, as applicable, to ensure that the manager's Compliance Test Report includes confirmation of compliance with this certification requirement, thereby incorporating this obligation into the periodic compliance reporting framework.
Prescribes an eligibility criterion under the AIF Regulations requiring the Compliance Officer of the Manager of an AIF to obtain NISM Series-III-C: Securities Intermediaries Compliance (Fund) certification by passing the specified examination, with managers required from 1 January 2027 to appoint or retain only certified persons as Compliance Officers, thereby rendering uncertified persons ineligible to be appointed or to continue in that role from that date. Requires the trustee/sponsor/manager, as applicable, to ensure that the manager's Compliance Test Report includes confirmation of compliance with this certification requirement, thereby incorporating this obligation into the periodic compliance reporting framework.
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