Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Revised reporting formats for External Commercial Borrowing have been prescribed: Part V Annex I and Annex II of the Master Direction are substituted with revised Form ECB 1 and Form ECB 2 reflecting the amended ECB framework. The forms capture borrower and lender details, loan registration, receipt, utilisation, debt servicing, hedging and closure of LRN information; available ECB limit and end use, security and interest rate particulars are included. The directions implement the procedural reporting changes consequent to the Foreign Exchange Management (Borrowing and Lending) amendment and are issued under sections 10(4), 11(1) and 11(2) of FEMA, with immediate effect.
Revised reporting formats for External Commercial Borrowing have been prescribed: Part V Annex I and Annex II of the Master Direction are substituted with revised Form ECB 1 and Form ECB 2 reflecting the amended ECB framework. The forms capture borrower and lender details, loan registration, receipt, utilisation, debt servicing, hedging and closure of LRN information; available ECB limit and end use, security and interest rate particulars are included. The directions implement the procedural reporting changes consequent to the Foreign Exchange Management (Borrowing and Lending) amendment and are issued under sections 10(4), 11(1) and 11(2) of FEMA, with immediate effect.
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