Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Allowability of interest on Compulsorily Convertible Debentures (CCDs) for period before conversion - RBI policy of FDI is governed by future repayment obligation and CCDs does not have any repayment obligation, hence considered by RBI as equity for FDI policy - CCDs holder neither eligible to voting nor dividend till its conversion hence CCDs are to be considered as Debt only and interest is allowable u/s 36 (1)(iii)
Allowability of interest on Compulsorily Convertible Debentures (CCDs) for period before conversion - RBI policy of FDI is governed by future repayment obligation and CCDs does not have any repayment obligation, hence considered by RBI as equity for FDI policy - CCDs holder neither eligible to voting nor dividend till its conversion hence CCDs are to be considered as Debt only and interest is allowable u/s 36 (1)(iii)
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