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...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
The amendment revises the Foreign Exchange Management (Non-debt Instruments) Rules, 2019 to tighten foreign investment controls for investors linked to countries sharing a land border with India. Such investors, and investors whose beneficial ownership falls within those restrictions, may invest only under the Government route; citizens or entities of Pakistan are also confined to the Government route in sectors other than defence, space, atomic energy and other prohibited activities. Any direct or indirect transfer that brings beneficial ownership within these restrictions requires prior Government approval. The amendment also clarifies beneficial ownership concepts, exempts multilateral banks or funds of which India is a member from country attribution, introduces reporting for certain permitted investments, and treats participating interest or rights in oil fields as foreign investment subject to Schedule I.
The amendment revises the Foreign Exchange Management (Non-debt Instruments) Rules, 2019 to tighten foreign investment controls for investors linked to countries sharing a land border with India. Such investors, and investors whose beneficial ownership falls within those restrictions, may invest only under the Government route; citizens or entities of Pakistan are also confined to the Government route in sectors other than defence, space, atomic energy and other prohibited activities. Any direct or indirect transfer that brings beneficial ownership within these restrictions requires prior Government approval. The amendment also clarifies beneficial ownership concepts, exempts multilateral banks or funds of which India is a member from country attribution, introduces reporting for certain permitted investments, and treats participating interest or rights in oil fields as foreign investment subject to Schedule I.
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