Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
Alternative statutory remedy and unexplained delay barred writ review of customs confiscation adjudication, leaving merits for appellate consideration...
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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.
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