Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
Page of 4894
Press 'Enter' after typing page number.
1441 to 1460 of 97867 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Section 56(2)(viib) applies when consideration is received for the issue of shares. Fully and compulsorily convertible debentures retain their character as debentures until conversion; compulsory future conversion does not treat them as shares on the date consideration is received. Neither section 56(2)(viib) nor Rule 11UA creates a deeming rule that classifies unconverted FCCDs as shares. The original issue of convertible debentures and the later issue of shares on conversion are distinct events, and conversion without fresh consideration does not independently trigger the provision. Regulatory or insolvency classifications cannot expand the charging language of the Income-tax Act.
Section 56(2)(viib) applies when consideration is received for the issue of shares. Fully and compulsorily convertible debentures retain their character as debentures until conversion; compulsory future conversion does not treat them as shares on the date consideration is received. Neither section 56(2)(viib) nor Rule 11UA creates a deeming rule that classifies unconverted FCCDs as shares. The original issue of convertible debentures and the later issue of shares on conversion are distinct events, and conversion without fresh consideration does not independently trigger the provision. Regulatory or insolvency classifications cannot expand the charging language of the Income-tax Act.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
