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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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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