I am having query regarding Master File Documentation in India Form 3CEAA. In Form 3CEAA, there is a clause no. 10 in which we have to report "Detailed descripttion of the financing arrangements of the international group, including the names and addresses of the top ten unrelated lenders".
Query is that whether we should consider lenders as on 31st December of FY or we should also include facility sanctioned by some lenders.
To answer your query: -
Consider lenders as on 31st December of the financial year (FY) for reporting purposes. -
Include facilities sanctioned by lenders during the FY, even if they are not yet drawn or utilized. - Report the top ten unrelated lenders based on the amount of financing (-sanctioned or drawn) as on 31st December of the FY. In other words, you should consider the lenders as on 31st December of the FY and include all facilities sanctioned during the FY, even if they are not yet drawn or utilized.
This will give a comprehensive picture of the financing arrangements of the international group as on the reporting date.
However, please consult the latest CBDT (Central Board of Direct Taxes) guidelines or the Income-tax website for any updates or clarifications on this matter.
Triveni Turbine Limited
Bengaluru
CA
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