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...
Reporting obligations for External Commercial Borrowing returns under FEMA are revised to classify Form ECB 1 and Revised Form ECB 1 as returns that do not capture flows, so late submission fee is to be computed accordingly. Each delayed Form ECB 2 submission under a Loan Registration Number is to be treated as a separate return for the fixed component of late submission fee. Designated AD Category I banks must forward complete returns received from eligible borrowers, with certification, to the Reserve Bank within seven calendar days, and must monitor customer payment of applicable late submission fee where submissions are delayed. The revised directions apply from 1 April 2026.
Reporting obligations for External Commercial Borrowing returns under FEMA are revised to classify Form ECB 1 and Revised Form ECB 1 as returns that do not capture flows, so late submission fee is to be computed accordingly. Each delayed Form ECB 2 submission under a Loan Registration Number is to be treated as a separate return for the fixed component of late submission fee. Designated AD Category I banks must forward complete returns received from eligible borrowers, with certification, to the Reserve Bank within seven calendar days, and must monitor customer payment of applicable late submission fee where submissions are delayed. The revised directions apply from 1 April 2026.
Note: It is a system-generated summary and is for quick reference only.