Self-assessed import entries remain appealable, while bona fide classification disputes without misdeclaration cannot justify confiscation or penaltie...
Actual-user customs exemption conditions permit turnkey project transfers when imported windmill components are exclusively used for installation and ...
Customs offence disqualification excludes civil contraventions, preventing refusal of a private bonded warehouse licence based solely on monetary pena...
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.