Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
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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