Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
Automotive radio classification treats integrated infotainment features as supplementary, placing complete and qualifying unassembled units under the ...
Separate corporate personality prevents directors from being personally liable for company deposits without a guarantee or independent legal undertaki...
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Portfolio managers must register as body corporates, maintain prescribed net worth, infrastructure, qualified personnel and continuing fit-and-proper status, while meeting client-grievance, disclosure and change-in-control obligations. Client arrangements require written investment agreements, pre-contract disclosure documents, transparent fees without assured returns or upfront charges, fiduciary conduct and segregation of client assets. Investment activity is subject to client mandates, prudential limits, restrictions on related-party and prohibited transactions, custody, records, audit, periodic reporting and compliance oversight. Special regimes govern eligible fund managers, co-investment managers and mutual-fund-only services. Inspection, disciplinary action, limited procedural relaxation and sandbox exemptions apply. Effective 1 April 2027, the framework repeals the 2020 regulations while preserving accrued rights and ongoing proceedings.
Portfolio managers must register as body corporates, maintain prescribed net worth, infrastructure, qualified personnel and continuing fit-and-proper status, while meeting client-grievance, disclosure and change-in-control obligations. Client arrangements require written investment agreements, pre-contract disclosure documents, transparent fees without assured returns or upfront charges, fiduciary conduct and segregation of client assets. Investment activity is subject to client mandates, prudential limits, restrictions on related-party and prohibited transactions, custody, records, audit, periodic reporting and compliance oversight. Special regimes govern eligible fund managers, co-investment managers and mutual-fund-only services. Inspection, disciplinary action, limited procedural relaxation and sandbox exemptions apply. Effective 1 April 2027, the framework repeals the 2020 regulations while preserving accrued rights and ongoing proceedings.
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