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...
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.
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