Blocked input tax credit for resort construction remains unavailable; interest follows actual utilisation, while delayed payment attracts statutory pe...
Duplicate PAN allocation requires record verification and deactivation reasons before assessment-related transactions can be attributed to an assessee...
Faceless assessment safeguards require requested personal hearings and adequate final show-cause response time, failing which reassessment is required...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
