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...
RBI has amended the Master Direction on non-resident investment in debt instruments by consolidating earlier instructions on NRI investment in debt instruments and the use of debt instruments acquired under FEMA 396 as collateral with recognised stock exchanges for exchange traded derivative transactions. The updated Master Direction is enclosed for authorised dealer Category-I banks, which are to circulate the changes to concerned constituents and customers. The circular is issued under the Foreign Exchange Management Act, 1999 and operates without prejudice to approvals required under any other law.
RBI has amended the Master Direction on non-resident investment in debt instruments by consolidating earlier instructions on NRI investment in debt instruments and the use of debt instruments acquired under FEMA 396 as collateral with recognised stock exchanges for exchange traded derivative transactions. The updated Master Direction is enclosed for authorised dealer Category-I banks, which are to circulate the changes to concerned constituents and customers. The circular is issued under the Foreign Exchange Management Act, 1999 and operates without prejudice to approvals required under any other law.
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