Arrest safeguards and transit remand requirements invalidated detention following inter-State transfer without communicated grounds or magistrate auth...
Arrest safeguards require disclosed grounds, relative intimation and transit remand, while duplicate prosecution under the CGST framework is unsustain...
Document Identification Number defects can invalidate GST assessments, with delayed challenges entertained conditionally where patent irregularities e...
Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
Non-recourse assignment of future rent receivables to financiers constitutes a sale of receivables rather than borrowing where the financier can proceed only against the renter and the assignor bears no repayment obligation. The difference between aggregate future rentals and the consideration received is therefore negotiated sale consideration, not interest under section 2(28A), and accounting treatment cannot alter that legal character. Since no borrowing or interest payment existed, section 194A did not apply; the assessee could not be treated as in default under section 201(1) or charged interest under section 201(1A). The related demands for the assessment years 2018-19 to 2024-25 were deleted.
Non-recourse assignment of future rent receivables to financiers constitutes a sale of receivables rather than borrowing where the financier can proceed only against the renter and the assignor bears no repayment obligation. The difference between aggregate future rentals and the consideration received is therefore negotiated sale consideration, not interest under section 2(28A), and accounting treatment cannot alter that legal character. Since no borrowing or interest payment existed, section 194A did not apply; the assessee could not be treated as in default under section 201(1) or charged interest under section 201(1A). The related demands for the assessment years 2018-19 to 2024-25 were deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4786
Join Channel
TaxTMI 
