Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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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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