Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
A pension fund is specified as a "specified person" for purposes of section 10(23FE) in respect of eligible investments made in India from the notification's publication date up to 31 March 2030, subject to compliance with prescribed conditions. The conditions require timely filing of income-tax returns for all relevant previous years until liquidation of the investment, quarterly reporting of investment details in Form 10BBB, furnishing an accountant's certificate in Form 10BBC, maintaining segmented accounts for exempt investment income and expenditure, continued foreign regulatory status, and limiting activities and asset use to qualifying retirement-type purposes, including prohibitions on borrowings for Indian investments and on day-to-day operational participation in investees. Breach of any condition renders the fund ineligible for the exemption.
A pension fund is specified as a "specified person" for purposes of section 10(23FE) in respect of eligible investments made in India from the notification's publication date up to 31 March 2030, subject to compliance with prescribed conditions. The conditions require timely filing of income-tax returns for all relevant previous years until liquidation of the investment, quarterly reporting of investment details in Form 10BBB, furnishing an accountant's certificate in Form 10BBC, maintaining segmented accounts for exempt investment income and expenditure, continued foreign regulatory status, and limiting activities and asset use to qualifying retirement-type purposes, including prohibitions on borrowings for Indian investments and on day-to-day operational participation in investees. Breach of any condition renders the fund ineligible for the exemption.
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