Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
After amendment to Explanation 1(c), eligibility as a venture capital undertaking must be determined strictly with reference to the SEBI Venture Capital Fund Regulations, 1996; on that regulatory and factual matrix the entity in question meets the regulatory description and is not within the negative list, so statutory eligibility is satisfied. Denial of exemption solely because commercial hospital operations had not commenced was rejected as inconsistent with the legislative aim to promote capital in sectors with inherent gestation. The income from the fund's qualifying investments therefore qualified for the statutory tax exemption.
After amendment to Explanation 1(c), eligibility as a venture capital undertaking must be determined strictly with reference to the SEBI Venture Capital Fund Regulations, 1996; on that regulatory and factual matrix the entity in question meets the regulatory description and is not within the negative list, so statutory eligibility is satisfied. Denial of exemption solely because commercial hospital operations had not commenced was rejected as inconsistent with the legislative aim to promote capital in sectors with inherent gestation. The income from the fund's qualifying investments therefore qualified for the statutory tax exemption.
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