Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Characterization of income - cash receipt due to waiver of loan by the state government - whether in the nature of subsidy - to be treated as benefit / perquisite u/s 28(iv) or not - there is a fundamental difference between “loan” and “subsidy” and the two concepts cannot be equated. While “loan” is a borrowing of money required to the repaid back with interest; “subsidy” is not required to be repaid back being a grant - even if a “loan” is written off or waived, which can be for various reasons, it cannot partake the character of a “subsidy” - No additions - HC
Characterization of income - cash receipt due to waiver of loan by the state government - whether in the nature of subsidy - to be treated as benefit / perquisite u/s 28(iv) or not - there is a fundamental difference between “loan” and “subsidy” and the two concepts cannot be equated. While “loan” is a borrowing of money required to the repaid back with interest; “subsidy” is not required to be repaid back being a grant - even if a “loan” is written off or waived, which can be for various reasons, it cannot partake the character of a “subsidy” - No additions - HC
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