Sufficient cause for delayed revenue income-tax appeals requires bona fides, due diligence and a credible explanation; otherwise limitation bars appea...
Inverted-duty-structure refunds remain available for unchanged-rate apparel supplies despite trader status and require tax-period-specific computation...
Foundational assessment satisfaction is essential before initiating penalty for cash receipt of immovable-property sale consideration under section 27...
Compulsorily convertible debentures, despite their hybrid features, retain their character as debt until conversion into shares. Transfer-pricing authorities cannot treat such instruments as equity solely from their features and fix the arm's length price of related interest at nil. Debt-to-equity recharacterisation is contemplated under Chapter X-A only after an impermissible avoidance arrangement is declared through the prescribed procedure. As no such procedure was invoked, the recharacterisation and resulting transfer-pricing adjustment were deleted, and the appeal was allowed.
Compulsorily convertible debentures, despite their hybrid features, retain their character as debt until conversion into shares. Transfer-pricing authorities cannot treat such instruments as equity solely from their features and fix the arm's length price of related interest at nil. Debt-to-equity recharacterisation is contemplated under Chapter X-A only after an impermissible avoidance arrangement is declared through the prescribed procedure. As no such procedure was invoked, the recharacterisation and resulting transfer-pricing adjustment were deleted, and the appeal was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
