Fraud classification show-cause notices founded on inconclusive forensic audit material cannot sustain action, permitting fresh proceedings on conclus...
Appellate enhancement limits protect against new income sources, while documented credits and prior-year investments resist unexplained-income additio...
Transfer-pricing treatment of compulsorily convertible debentures turns on their legal status until actual conversion or redemption. Ind AS presentation of a component as equity within a compound financial instrument does not by itself change outstanding debentures from debt; interest remains allowable where reclassification is solely for financial-reporting purposes, subject to verification of conversion or redemption. Notional interest on delayed associated-enterprise receivables should not be imputed where comparable non-associated customers receive the same no-interest treatment and the taxpayer applies that practice consistently. The relevant principle is commercial uniformity across comparable transactions.
Transfer-pricing treatment of compulsorily convertible debentures turns on their legal status until actual conversion or redemption. Ind AS presentation of a component as equity within a compound financial instrument does not by itself change outstanding debentures from debt; interest remains allowable where reclassification is solely for financial-reporting purposes, subject to verification of conversion or redemption. Notional interest on delayed associated-enterprise receivables should not be imputed where comparable non-associated customers receive the same no-interest treatment and the taxpayer applies that practice consistently. The relevant principle is commercial uniformity across comparable transactions.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
