Commitment proceedings gain extended timelines, structured defect refiling, and automatic resumption of inquiry after the adjusted completion period e...
Centralised assessment transfer becomes unwarranted once the searched person's assessment is complete, requiring restoration to the appropriate charge...
Co-operative deduction eligibility excludes refund and commercial-bank interest, while qualifying co-operative investments require entity-wise verific...
Enhanced tax rate on surrendered unexplained income applies prospectively, while cash-deposit telescoping requires verification of available surrender...
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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.
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