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...
Foundational assessment satisfaction is essential before initiating penalty for cash receipt of immovable-property sale consideration under section 27...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
