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...
Amendments revise the Borrowing and Lending Regulations to redefine key terms, introduce explicit end-use restrictions (prohibiting funds for chit funds, nidhi companies, specified real estate uses, most agricultural activities, TDR trading, securities trading except strategic corporate actions, repayment of certain domestic INR loans, and prohibited on lending) and update the External Commercial Borrowing (ECB) framework. The ECB framework clarifies eligible borrowers and lenders, currency and form flexibility, borrowing limits, minimum average maturity period requirements, cost and security provisions, conversion to non debt instruments, refinancing rules, reporting obligations including Loan Registration Number procedures and treatment of untraceable borrowers, and related prudential and disclosure conditions.
Amendments revise the Borrowing and Lending Regulations to redefine key terms, introduce explicit end-use restrictions (prohibiting funds for chit funds, nidhi companies, specified real estate uses, most agricultural activities, TDR trading, securities trading except strategic corporate actions, repayment of certain domestic INR loans, and prohibited on lending) and update the External Commercial Borrowing (ECB) framework. The ECB framework clarifies eligible borrowers and lenders, currency and form flexibility, borrowing limits, minimum average maturity period requirements, cost and security provisions, conversion to non debt instruments, refinancing rules, reporting obligations including Loan Registration Number procedures and treatment of untraceable borrowers, and related prudential and disclosure conditions.
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