Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from...
Transfer-pricing benchmarking confines adjustments to associated-enterprise transactions and integrates delayed receivables through TNMM working-capit...
Medical relief status protects government-contracted mobile healthcare from commercial classification, while provisional registration cancellation req...
Charitable registration cancellation requires proof that educational activities abandoned their objects; incidental receipts and retained surplus are ...
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 4884 
