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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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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