Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes...
Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
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Book-entry conversion of compulsorily convertible debentures into compulsorily convertible preference shares did not constitute a sum received during the relevant previous year for the cash-credit provision. Share premium arising solely from that conversion therefore could not be treated as an unexplained cash credit, rendering the related addition unsustainable. Penalty founded solely on the deleted share-premium addition had no surviving basis. Penalty for non-reporting income also did not arise for principal additions that were set aside; for additions remanded for fresh consideration, penalty could be considered only if they were reiterated. The Revenue's appeals were dismissed for want of a substantial question of law.
Book-entry conversion of compulsorily convertible debentures into compulsorily convertible preference shares did not constitute a sum received during the relevant previous year for the cash-credit provision. Share premium arising solely from that conversion therefore could not be treated as an unexplained cash credit, rendering the related addition unsustainable. Penalty founded solely on the deleted share-premium addition had no surviving basis. Penalty for non-reporting income also did not arise for principal additions that were set aside; for additions remanded for fresh consideration, penalty could be considered only if they were reiterated. The Revenue's appeals were dismissed for want of a substantial question of law.
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