Political contribution deductions require genuine transactions; banking records and party registration alone cannot defeat evidence of accommodation e...
Post-death GST liability permits fresh proceedings against legal representatives, while discontinued-business recovery remains limited to the inherite...
Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
Compulsorily convertible debentures, despite their hybrid features, retain their character as debt until conversion into shares. Transfer-pricing authorities cannot treat such instruments as equity solely from their features and fix the arm's length price of related interest at nil. Debt-to-equity recharacterisation is contemplated under Chapter X-A only after an impermissible avoidance arrangement is declared through the prescribed procedure. As no such procedure was invoked, the recharacterisation and resulting transfer-pricing adjustment were deleted, and the appeal was allowed.
Compulsorily convertible debentures, despite their hybrid features, retain their character as debt until conversion into shares. Transfer-pricing authorities cannot treat such instruments as equity solely from their features and fix the arm's length price of related interest at nil. Debt-to-equity recharacterisation is contemplated under Chapter X-A only after an impermissible avoidance arrangement is declared through the prescribed procedure. As no such procedure was invoked, the recharacterisation and resulting transfer-pricing adjustment were deleted, and the appeal was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
