Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
Deduction for premium paid on redemption of optionally convertible debentures (OCDs) u/s 37 was disallowed. The Tribunal found no obligation existed for the assessee to redeem the OCDs during the relevant previous year, at the time of finalizing accounts, or even when filing the return. No payment towards redemption or premium was made during that year. Therefore, the assessee could not claim deduction either on accrual or paid basis for that year. Since the OCDs were not in existence during the relevant year, allowing deduction for proportionate redemption premium as interest did not arise. The decision went against the assessee.
Deduction for premium paid on redemption of optionally convertible debentures (OCDs) u/s 37 was disallowed. The Tribunal found no obligation existed for the assessee to redeem the OCDs during the relevant previous year, at the time of finalizing accounts, or even when filing the return. No payment towards redemption or premium was made during that year. Therefore, the assessee could not claim deduction either on accrual or paid basis for that year. Since the OCDs were not in existence during the relevant year, allowing deduction for proportionate redemption premium as interest did not arise. The decision went against the assessee.
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