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...
Redemption premium on foreign currency convertible bonds issued to raise and use business funds is characterised as revenue expenditure, because the liability arises on issuance and does not acquire a capital asset or enduring advantage. The notes state that expenditure connected with issuing debentures or obtaining loans is likewise revenue in nature. The premium liability arises in the year of issue and may be proportionately spread over the bonds' prescribed maturity period; it is immaterial whether redemption is at will or only at maturity. The text further records that no substantial question of law arose on either the revenue character or timing of the deduction.
Redemption premium on foreign currency convertible bonds issued to raise and use business funds is characterised as revenue expenditure, because the liability arises on issuance and does not acquire a capital asset or enduring advantage. The notes state that expenditure connected with issuing debentures or obtaining loans is likewise revenue in nature. The premium liability arises in the year of issue and may be proportionately spread over the bonds' prescribed maturity period; it is immaterial whether redemption is at will or only at maturity. The text further records that no substantial question of law arose on either the revenue character or timing of the deduction.
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