Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
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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