Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
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.
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