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...
SEBI has expanded the permissible use of fresh borrowings by InvITs where net borrowings exceed 49% of InvIT asset value. The borrowings may now be used for capital expenditure to enhance asset performance or augment capacity, for major maintenance expenses in road projects, and for refinancing debt by the InvIT, SPV or Holdco. Major maintenance is limited to non-routine maintenance required under the concession agreement, and road project is confined to the notified roads and bridges infrastructure sub-sector. Refinancing is permitted only for the principal portion of eligible original debt; accumulated interest, charges and fees cannot be refinanced. The circular takes immediate effect.
SEBI has expanded the permissible use of fresh borrowings by InvITs where net borrowings exceed 49% of InvIT asset value. The borrowings may now be used for capital expenditure to enhance asset performance or augment capacity, for major maintenance expenses in road projects, and for refinancing debt by the InvIT, SPV or Holdco. Major maintenance is limited to non-routine maintenance required under the concession agreement, and road project is confined to the notified roads and bridges infrastructure sub-sector. Refinancing is permitted only for the principal portion of eligible original debt; accumulated interest, charges and fees cannot be refinanced. The circular takes immediate effect.
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