Road restoration charges constitute taxable services when requested for commercial pipeline activity, requiring reverse-charge GST from the business r...
Interest on delayed release of requisitioned cash includes statutory pre-assessment interest and restitutionary compensation for unlawful post-assessm...
Incomplete inventory records justify rejecting accounts, while profit estimation requires relevant comparable material and interest falls under other ...
Transfer-pricing comparability requires functional alignment; delayed associated-enterprise receivables need separate LIBOR-based benchmarking, while ...
Extended reassessment limitation in search cases requires asset-linked escaped income, invalidating additions based only on unexplained money or expen...
Enhanced tolerance band under section 43CA applies retrospectively, deleting qualifying deemed-sale additions while disputed stamp valuation requires ...
Section 56(2)(viib) applies when consideration is received for the issue of shares. Fully and compulsorily convertible debentures retain their character as debentures until conversion; compulsory future conversion does not treat them as shares on the date consideration is received. Neither section 56(2)(viib) nor Rule 11UA creates a deeming rule that classifies unconverted FCCDs as shares. The original issue of convertible debentures and the later issue of shares on conversion are distinct events, and conversion without fresh consideration does not independently trigger the provision. Regulatory or insolvency classifications cannot expand the charging language of the Income-tax Act.
Section 56(2)(viib) applies when consideration is received for the issue of shares. Fully and compulsorily convertible debentures retain their character as debentures until conversion; compulsory future conversion does not treat them as shares on the date consideration is received. Neither section 56(2)(viib) nor Rule 11UA creates a deeming rule that classifies unconverted FCCDs as shares. The original issue of convertible debentures and the later issue of shares on conversion are distinct events, and conversion without fresh consideration does not independently trigger the provision. Regulatory or insolvency classifications cannot expand the charging language of the Income-tax Act.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
