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...
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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