Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
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.
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