Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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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