Regulatory consolidation for investment advisers: SEBI issues master circular consolidating guidance and prescribing compliance, reporting, fees and s...
Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
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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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