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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These Regulations (superseding the 2015 rules) require exporters to file an Export Declaration Form (EDF) with the specified authority and, for non-EDI cases, transmit authenticated EDFs to the Authorised Dealer (AD), thereby formalising export declarations and linkage to ADs; they prescribe realisation periods-generally 15 months (18 months if invoiced/settled in INR) and contract-specific terms for project exports-thereby fixing time limits for repatriation; empower ADs to verify genuineness before credit/debit and to close or update EDPMS/IDPMS entries, thereby imposing AD monitoring and reporting duties; permit ADs to allow reduction in export realisation, set-off of export receivables against import payables, third-party receipts/payments, and controlled advance remittances (with restrictions for gold/silver), thereby regulating adjustments and advance flows; impose reporting timelines for EDPMS/IDPMS and require ADs to maintain internal policies/SOPs, thereby mandating compliance, monitoring and customer grievance/appeal mechanisms.
These Regulations (superseding the 2015 rules) require exporters to file an Export Declaration Form (EDF) with the specified authority and, for non-EDI cases, transmit authenticated EDFs to the Authorised Dealer (AD), thereby formalising export declarations and linkage to ADs; they prescribe realisation periods-generally 15 months (18 months if invoiced/settled in INR) and contract-specific terms for project exports-thereby fixing time limits for repatriation; empower ADs to verify genuineness before credit/debit and to close or update EDPMS/IDPMS entries, thereby imposing AD monitoring and reporting duties; permit ADs to allow reduction in export realisation, set-off of export receivables against import payables, third-party receipts/payments, and controlled advance remittances (with restrictions for gold/silver), thereby regulating adjustments and advance flows; impose reporting timelines for EDPMS/IDPMS and require ADs to maintain internal policies/SOPs, thereby mandating compliance, monitoring and customer grievance/appeal mechanisms.
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