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...
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.