Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Amendments revise eligibility and scope: export credit qualifies only if extended in accordance with RBI consolidated Directions on Credit Facilities, and interest subvention applies to the interest cost actually borne by eligible MSME exporters, resulting in subvention limited to the recorded interest component. Temporal application: revised subvention rates apply only to facilities sanctioned on or after notification, with existing facilities governed by the rate at sanction; subvention admissible only for export credit sanctioned on or after 02.01.2026. Exclusions and conditions: no subvention for deemed exports or where the account turns NPA before the export cycle; exporters reclassified out of MSME remain eligible for three years post-reclassification. Administrative and financial controls: beneficiary bears responsibility for aggregate annual ceiling and excess recoverable; reimbursements to banks limited to verified actual subvention and claimed monthly; banks must submit IEC-wise online claims and reports within fifteen days; the FY 2025-26 annual ceiling applies in full without pro rata adjustment.
Amendments revise eligibility and scope: export credit qualifies only if extended in accordance with RBI consolidated Directions on Credit Facilities, and interest subvention applies to the interest cost actually borne by eligible MSME exporters, resulting in subvention limited to the recorded interest component. Temporal application: revised subvention rates apply only to facilities sanctioned on or after notification, with existing facilities governed by the rate at sanction; subvention admissible only for export credit sanctioned on or after 02.01.2026. Exclusions and conditions: no subvention for deemed exports or where the account turns NPA before the export cycle; exporters reclassified out of MSME remain eligible for three years post-reclassification. Administrative and financial controls: beneficiary bears responsibility for aggregate annual ceiling and excess recoverable; reimbursements to banks limited to verified actual subvention and claimed monthly; banks must submit IEC-wise online claims and reports within fifteen days; the FY 2025-26 annual ceiling applies in full without pro rata adjustment.
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