Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Capital gains tax exemption bonds issued u/s 54EC of the Income Tax Act, 1961, are long-term specified assets with a mandatory lock-in period of 5 years. The legislative intent behind this lock-in period is to ensure long-term capital allocation and financial stability. The bonds cannot be transferred, converted into money, or used as security for a loan within the lock-in period, as it would violate the statutory purpose and contractual terms. Premature cancellation or redemption of these bonds is not permissible, even if the capital gains exemption is not claimed or the investor is willing to forgo interest. Allowing such premature redemption would undermine the object and purpose of the bond scheme and contravene statutory obligations u/s 54EC. The terms and conditions governing the bonds are binding on both parties, and cannot be unilaterally altered or modified through judicial intervention under Article 226 of the Constitution.
Capital gains tax exemption bonds issued u/s 54EC of the Income Tax Act, 1961, are long-term specified assets with a mandatory lock-in period of 5 years. The legislative intent behind this lock-in period is to ensure long-term capital allocation and financial stability. The bonds cannot be transferred, converted into money, or used as security for a loan within the lock-in period, as it would violate the statutory purpose and contractual terms. Premature cancellation or redemption of these bonds is not permissible, even if the capital gains exemption is not claimed or the investor is willing to forgo interest. Allowing such premature redemption would undermine the object and purpose of the bond scheme and contravene statutory obligations u/s 54EC. The terms and conditions governing the bonds are binding on both parties, and cannot be unilaterally altered or modified through judicial intervention under Article 226 of the Constitution.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4878 
