Political contribution deductions require genuine transactions; banking records and party registration alone cannot defeat evidence of accommodation e...
Post-death GST liability permits fresh proceedings against legal representatives, while discontinued-business recovery remains limited to the inherite...
Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
Fully and compulsorily convertible debentures retain debt character until conversion, so pre-conversion interest cannot be benchmarked at nil by recharacterising them as equity. The transfer pricing authorities had not carried out an independent benchmarking exercise, so the arm's length price of the interest was remitted for fresh determination. For receivables from associated enterprises, notional interest was upheld in principle, but the adjustment had to be recomputed after allowing a 90-day credit period.
Fully and compulsorily convertible debentures retain debt character until conversion, so pre-conversion interest cannot be benchmarked at nil by recharacterising them as equity. The transfer pricing authorities had not carried out an independent benchmarking exercise, so the arm's length price of the interest was remitted for fresh determination. For receivables from associated enterprises, notional interest was upheld in principle, but the adjustment had to be recomputed after allowing a 90-day credit period.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
