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...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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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