Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
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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