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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The instrument establishes new Foreign Exchange Management (Guarantees) Regulations, 2026, directing AD Category I banks to apply those regulations when facilitating guarantees involving any person resident outside India, thereby making those regulations the operative compliance standard for such guarantees. It prescribes comprehensive reporting of all guarantees (issued, modified or invoked) to authorised dealer banks in a prescribed GRN form, thereby imposing a mandatory reporting obligation and requiring banks to submit compiled returns in a future-specified manner. It expressly supersedes the listed A.P. (DIR Series) circulars-except for past actions-thereby withdrawing prior circular guidance; discontinues quarterly reporting on Trade Credit guarantees from quarter ending March 2026, thereby ending that specific reporting obligation; and amends guarantee provisions in multiple Master Directions, thereby altering existing regulatory provisions governing guarantees. (RBI)
The instrument establishes new Foreign Exchange Management (Guarantees) Regulations, 2026, directing AD Category I banks to apply those regulations when facilitating guarantees involving any person resident outside India, thereby making those regulations the operative compliance standard for such guarantees. It prescribes comprehensive reporting of all guarantees (issued, modified or invoked) to authorised dealer banks in a prescribed GRN form, thereby imposing a mandatory reporting obligation and requiring banks to submit compiled returns in a future-specified manner. It expressly supersedes the listed A.P. (DIR Series) circulars-except for past actions-thereby withdrawing prior circular guidance; discontinues quarterly reporting on Trade Credit guarantees from quarter ending March 2026, thereby ending that specific reporting obligation; and amends guarantee provisions in multiple Master Directions, thereby altering existing regulatory provisions governing guarantees. (RBI)
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