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...
Employee conflict disclosures and investment restrictions expand with new recusal duties, post-employment limits, and compliance reporting requirement...
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.
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