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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Interest subvention support under the Export Promotion Mission is clarified to apply only to eligible export credit disbursed on or after 2 January 2026, and not to earlier disbursements. Eligibility depends on UIN/UDIN generation and submission on the disbursement date; if no UIN is generated, the disbursal is outside the scheme. A new UIN is required on change of lending bank, portability is barred, and subvention stops from the date an account is classified as NPA. The notice also limits cross-bank claims to the prescribed annual ceiling, fixes subvention to the rate prevailing on disbursement, and provides that early foreclosure and renewed top-up credit are to be treated according to actual outstanding or fresh exposure.
Interest subvention support under the Export Promotion Mission is clarified to apply only to eligible export credit disbursed on or after 2 January 2026, and not to earlier disbursements. Eligibility depends on UIN/UDIN generation and submission on the disbursement date; if no UIN is generated, the disbursal is outside the scheme. A new UIN is required on change of lending bank, portability is barred, and subvention stops from the date an account is classified as NPA. The notice also limits cross-bank claims to the prescribed annual ceiling, fixes subvention to the rate prevailing on disbursement, and provides that early foreclosure and renewed top-up credit are to be treated according to actual outstanding or fresh exposure.
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