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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SEBI permits an AIF investment manager, pending receipt of an accreditation certificate, to execute the contribution agreement and commence related operational processes based on its assessment of an investor's eligibility, but the investor's commitment must be excluded from scheme corpus calculations until accreditation is obtained and the scheme may accept funds only after the accreditation certificate is issued, preserving corpus-based prudential norms. For net-worth based accreditation, the requirement to submit a detailed net-worth break-up as an annexure to the net-worth certificate is removed, and it is clarified that a chartered accountant may certify satisfaction of the prescribed threshold without stating the actual net worth, reducing documentary compliance. AIF trustee/sponsor/manager must ensure the Compliance Test Report covers compliance with these directions, effective immediately.
SEBI permits an AIF investment manager, pending receipt of an accreditation certificate, to execute the contribution agreement and commence related operational processes based on its assessment of an investor's eligibility, but the investor's commitment must be excluded from scheme corpus calculations until accreditation is obtained and the scheme may accept funds only after the accreditation certificate is issued, preserving corpus-based prudential norms. For net-worth based accreditation, the requirement to submit a detailed net-worth break-up as an annexure to the net-worth certificate is removed, and it is clarified that a chartered accountant may certify satisfaction of the prescribed threshold without stating the actual net worth, reducing documentary compliance. AIF trustee/sponsor/manager must ensure the Compliance Test Report covers compliance with these directions, effective immediately.
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