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...
FPIs may net fund obligations for outright cash-market transactions, meaning only a purchase or only a sale in a settlement cycle, while mixed purchase-and-sale trades remain settled on a gross basis. Securities settlement between the FPI and custodian continues on a gross basis, and STT and stamp duty remain chargeable on delivery basis. The earlier Master Circular framework is modified to that extent, implementation standards are to be framed by custodians and the CDSSF after stakeholder consultation, and market participants must update systems by 31 December 2026.
FPIs may net fund obligations for outright cash-market transactions, meaning only a purchase or only a sale in a settlement cycle, while mixed purchase-and-sale trades remain settled on a gross basis. Securities settlement between the FPI and custodian continues on a gross basis, and STT and stamp duty remain chargeable on delivery basis. The earlier Master Circular framework is modified to that extent, implementation standards are to be framed by custodians and the CDSSF after stakeholder consultation, and market participants must update systems by 31 December 2026.
Note: It is a system-generated summary and is for quick reference only.
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