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 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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