Employee stock-shortage penalties do not constitute consideration for services, preventing GST collection under Schedule II in employment relationship...
Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
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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.
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