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...
Foreign Portfolio Investor limits for FY 2026-27 in debt instruments are kept at 6% for G-Secs, 2% for SGSs and 15% for corporate bonds under the General Route, with the G-Sec incremental increase retained on a 50:50 split between General and Long-term sub-categories. The entire incremental increase in SGS limits is placed in the General sub-category, specified securities continue to be reckoned under the Fully Accessible Route, and investments under the Voluntary Retention Route are brought within the General Route limits from 1 April 2026. The circular also fixes the aggregate notional amount of Credit Default Swaps sold by FPIs at 5% of outstanding corporate bonds and withdraws the earlier 2025-26 circular.
Foreign Portfolio Investor limits for FY 2026-27 in debt instruments are kept at 6% for G-Secs, 2% for SGSs and 15% for corporate bonds under the General Route, with the G-Sec incremental increase retained on a 50:50 split between General and Long-term sub-categories. The entire incremental increase in SGS limits is placed in the General sub-category, specified securities continue to be reckoned under the Fully Accessible Route, and investments under the Voluntary Retention Route are brought within the General Route limits from 1 April 2026. The circular also fixes the aggregate notional amount of Credit Default Swaps sold by FPIs at 5% of outstanding corporate bonds and withdraws the earlier 2025-26 circular.
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