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...
Sale proceeds of Renewable Energy Certificates received by renewable-energy power generators are treated as capital receipts because the certificates incentivise environmental benefits of renewable generation rather than arise from producing or selling goods or rendering services. They therefore do not constitute business income or profits derived from an eligible power-generation undertaking for deduction purposes. As capital receipts, the proceeds are also excluded from book profit computed for minimum alternate tax purposes under section 115JB. The Revenue's challenge to deletion of the related disallowance and to exclusion from book profit was rejected.
Sale proceeds of Renewable Energy Certificates received by renewable-energy power generators are treated as capital receipts because the certificates incentivise environmental benefits of renewable generation rather than arise from producing or selling goods or rendering services. They therefore do not constitute business income or profits derived from an eligible power-generation undertaking for deduction purposes. As capital receipts, the proceeds are also excluded from book profit computed for minimum alternate tax purposes under section 115JB. The Revenue's challenge to deletion of the related disallowance and to exclusion from book profit was rejected.
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