Business expenditure and depreciation rules allow operational outgoings while limiting disallowances for personal elements and unsupported third-party...
Compromise-and-arrangement extensions may accommodate debt assignment where creditor commercial judgment supports value maximisation and avoids proced...
Delayed-payment surcharge is not taxable tolerance consideration where it penalises default, while meter testing follows electricity distribution trea...
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...
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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.
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