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    October 13, 2026   Case Laws Income Tax
    MAT credit succession on amalgamation allows a transferee to claim available unutilised credit under a sanctioned scheme, subject to verification.
    October 13, 2026   Case Laws Income Tax
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    October 13, 2026   Case Laws Income Tax
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October 13, 2026   Case Laws Income Tax
MAT credit succession on amalgamation allows a transferee to claim available unutilised credit under a sanctioned scheme, subject to verification.
October 13, 2026   Case Laws Income Tax
Advertisement expenditure as brand-promotion service requires proof of an arrangement; adjustment deleted and other tax computations remanded.
October 13, 2026   Case Laws Income Tax
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exemption.
October 13, 2026   Case Laws Income Tax
Notional interest on delayed trade receivables may be deleted when financial records verify the taxpayer is completely debt-free.
October 13, 2026   Case Laws Income Tax
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangements.
October 13, 2026   Case Laws Income Tax
Retracted search surrenders without corroboration cannot sustain undisclosed-income additions; no section 14A disallowance arises without exempt income.
October 13, 2026   Case Laws Income Tax
Charitable trust registration cancellation requires proof of non-genuine activities, while year-specific irregular receipts remain assessment matters.
October 13, 2026   Case Laws Benami Property
Benami cash routing through third-party bank accounts permits attachment of remaining balances and traceable converted funds.
October 13, 2026   Case Laws Customs
Rectification jurisdiction excludes merits review where objections challenge concluded penalty findings rather than patent errors on the record.
October 13, 2026   Case Laws Customs
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer penalties.
October 13, 2026   Case Laws Customs
Customs reassessment acceptance preserves challenge rights where transaction value is rejected solely on unsupported NIDB data.
October 13, 2026   Case Laws Customs
Furnace re-lining refractories qualify as EPCG capital goods, securing zero-duty import benefits and eliminating related customs demands.
October 13, 2026   Case Laws Customs
Automotive radio classification treats integrated infotainment features as supplementary, placing complete and qualifying unassembled units under the radio tariff heading.
October 13, 2026   Case Laws Customs
Storage-server classification determines end-use Basic Customs Duty exemption for qualifying imported manufacturing inputs, subject to prescribed conditions.
October 13, 2026   Case Laws Customs
Customs classification of battery insulating tape distinguishes dedicated die-cut accumulator parts from general-use self-adhesive rolls.
October 13, 2026   Case Laws Companies Law
Separate corporate personality prevents directors from being personally liable for company deposits without a guarantee or independent legal undertaking.
October 13, 2026   Case Laws IBC
Recall jurisdiction cannot cure affidavit defects or permit non-parties in disciplinary stay proceedings as parties.
October 13, 2026   Case Laws FEMA
Credit-rating conflict safeguards extend to promoter borrowers and subsidiaries, invalidating penalties based on a narrower interpretation.
October 13, 2026   Case Laws Money Laundering
Proceeds of Crime Tracing Supports Attachment Where Escrow Funds Fund Property Despite Intermingling With Other Money
October 13, 2026   Case Laws GST
Statutory pre-deposit enables tax appeals on merits, with prior deposits adjusted and balance demand stayed after compliance.

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Home › Highlights › Income Tax › 2026 › September, 2026 › This
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Income Tax

Transfer-pricing treatment of compulsorily convertible...

Compulsorily convertible debentures retain debt character until conversion, while uniform no-interest receivable practices resist transfer-pricing adjustments.

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Income Tax September 22, 2026 Case Laws AT
Transfer-pricing treatment of compulsorily convertible debentures turns on their legal status until actual conversion or redemption. Ind AS presentation of a component as equity within a compound financial instrument does not by itself change outstanding debentures from debt; interest remains allowable where reclassification is solely for financial-reporting purposes, subject to verification of conversion or redemption. Notional interest on delayed associated-enterprise receivables should not be imputed where comparable non-associated customers receive the same no-interest treatment and the taxpayer applies that practice consistently. The relevant principle is commercial uniformity across comparable transactions.
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