Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing rules require benchmarking the actual international transaction and generally prohibit re-characterising legally valid compulsorily convertible debentures as equity merely because another commercial structure appears preferable. Compulsory conversion, lack of repayment before conversion, and separate regulatory or accounting treatment do not alter their debt character until conversion. The nil arm's length price for interest was therefore set aside, with fresh benchmarking required using CUP or another permissible method. Bad debts written off are deductible where statutory conditions are met and debtor accounts are correspondingly extinguished; independent proof of irrecoverability is unnecessary. The bad-debt disallowance was deleted.
Transfer pricing rules require benchmarking the actual international transaction and generally prohibit re-characterising legally valid compulsorily convertible debentures as equity merely because another commercial structure appears preferable. Compulsory conversion, lack of repayment before conversion, and separate regulatory or accounting treatment do not alter their debt character until conversion. The nil arm's length price for interest was therefore set aside, with fresh benchmarking required using CUP or another permissible method. Bad debts written off are deductible where statutory conditions are met and debtor accounts are correspondingly extinguished; independent proof of irrecoverability is unnecessary. The bad-debt disallowance was deleted.
Note: It is a system-generated summary and is for quick reference only.