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...
Master Circular consolidates SEBI circulars governing Research Analysts, rescinding earlier circulars insofar as they relate to RAs while preserving prior actions and applications. It prescribes qualification and NISM certification rules, deposit tiers linked to client counts, registration rules including part time and dual IA/RA registration, mandatory disclosures (including AI use), model portfolio standards, client level segregation of research and distribution, fee ceilings for individual/HUF clients, KYC and record keeping, annual compliance audits and periodic reporting, administration/supervision by an RAASB (BSE designated), advertising code, outsourcing, AML/KYC, cybersecurity (CSCRF), PaRRVA verification regime and optional centralised fee collection (CeFCoM).
Master Circular consolidates SEBI circulars governing Research Analysts, rescinding earlier circulars insofar as they relate to RAs while preserving prior actions and applications. It prescribes qualification and NISM certification rules, deposit tiers linked to client counts, registration rules including part time and dual IA/RA registration, mandatory disclosures (including AI use), model portfolio standards, client level segregation of research and distribution, fee ceilings for individual/HUF clients, KYC and record keeping, annual compliance audits and periodic reporting, administration/supervision by an RAASB (BSE designated), advertising code, outsourcing, AML/KYC, cybersecurity (CSCRF), PaRRVA verification regime and optional centralised fee collection (CeFCoM).
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