Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
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Compulsorily convertible debentures remain debt until conversion, notwithstanding mandatory conversion, absence of principal repayment, regulatory classification or accounting treatment. Their interest must therefore be benchmarked as debt for arm's-length pricing; treating pre-conversion CCDs as equity and fixing interest at nil is unsustainable. Debt-equity recharacterisation is contemplated under Chapter X-A only where an arrangement is declared impermissible and the prescribed procedure is followed. As that procedure was not invoked, the transfer-pricing adjustment based on recharacterisation of unsecured CCDs as equity was deleted.
Compulsorily convertible debentures remain debt until conversion, notwithstanding mandatory conversion, absence of principal repayment, regulatory classification or accounting treatment. Their interest must therefore be benchmarked as debt for arm's-length pricing; treating pre-conversion CCDs as equity and fixing interest at nil is unsustainable. Debt-equity recharacterisation is contemplated under Chapter X-A only where an arrangement is declared impermissible and the prescribed procedure is followed. As that procedure was not invoked, the transfer-pricing adjustment based on recharacterisation of unsecured CCDs as equity was deleted.
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