Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Sovereign Wealth Funds seeking exemption under Schedule V of the Income-tax Act, 2025 must file Form I for notification and then file quarterly Form II statements for each investment within one month from quarter-end, together with return of income and audit report. SWFs already notified under the 1961 Act need not file a fresh Form I, but must still submit quarterly Form II statements. CBDT also requires the prescribed data structure, verification standards and security protocols for the forms. The circular takes effect from 1 April 2026 and applies from tax year 2026-27 onward.
Sovereign Wealth Funds seeking exemption under Schedule V of the Income-tax Act, 2025 must file Form I for notification and then file quarterly Form II statements for each investment within one month from quarter-end, together with return of income and audit report. SWFs already notified under the 1961 Act need not file a fresh Form I, but must still submit quarterly Form II statements. CBDT also requires the prescribed data structure, verification standards and security protocols for the forms. The circular takes effect from 1 April 2026 and applies from tax year 2026-27 onward.
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