Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
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...
INR non-deliverable derivative contracts may be offered by Authorised Dealers to non-resident users only for hedging, replacing the previous unrestricted-purpose position. Authorised Dealers must maintain a Foreign Exchange Risk Reserve for INR foreign exchange derivative contracts undertaken to hedge currency risk on their own assets and liabilities where they purchase foreign currency against INR. The reserve must equal 20 per cent of each contract's INR-equivalent notional amount, be maintained as a daily cash deposit in India with RBI until contract termination, and applies to contracts undertaken after issuance of the directions.
INR non-deliverable derivative contracts may be offered by Authorised Dealers to non-resident users only for hedging, replacing the previous unrestricted-purpose position. Authorised Dealers must maintain a Foreign Exchange Risk Reserve for INR foreign exchange derivative contracts undertaken to hedge currency risk on their own assets and liabilities where they purchase foreign currency against INR. The reserve must equal 20 per cent of each contract's INR-equivalent notional amount, be maintained as a daily cash deposit in India with RBI until contract termination, and applies to contracts undertaken after issuance of the directions.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
