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    September 17, 2026   Case Laws Income Tax
    Functional comparability under TNMM supports cross-industry distributor benchmarks for licence fees when FAR profiles align.
    September 17, 2026   Case Laws Income Tax
    Interest in an enforced foreign arbitral award becomes judgment debt and falls outside Indian income taxation.
    September 17, 2026   Case Laws Income Tax
    Penalty limitation under section 275(1)(c) runs from the show-cause notice where proceedings arise outside assessment proceedings.
    September 17, 2026   Case Laws Income Tax
    Banking tax treatment clarifies real-income recognition, securities valuation, bad-debt provisions and employee-benefit deductions across assessment i...
    September 17, 2026   Case Laws Income Tax
    Maximum marginal rate cannot govern public charitable association income assessed at normal Association of Persons rates.
    September 17, 2026   Case Laws Income Tax
    Rental income valuation requires credible local comparables; family-business salary and commercially expedient unsecured-loan interest remained deduct...
    September 17, 2026   Case Laws Income Tax
    Service permanent establishment requirements exclude remote cost-to-cost reimbursements from Indian tax where no personnel are physically present.
    September 17, 2026   Case Laws Income Tax
    Section 263 revision requires a genuine assessment error; unchecked borrowed-fund use warranted fresh interest-capitalisation examination.
    September 17, 2026   Case Laws Income Tax
    Tonnage tax shipping income excludes non-core receipts, while commercially expedient maritime sponsorship remains deductible business expenditure.
    September 17, 2026   Case Laws Income Tax
    Limitation for final assessment requires timely completion after time-barred DRP objections; otherwise, the assessment is void.
    September 17, 2026   Case Laws Income Tax
    Proof of cash receipt is essential before imposing penalties for alleged violations of cash-transaction restrictions.
    September 17, 2026   Case Laws Income Tax
    Foreign-contribution disclosure mismatches require substantive reconciliation, preventing automatic treatment of separately reported interest income a...
    September 17, 2026   Case Laws Income Tax
    Business expenditure after branch transfer requires verification of retained assets and related legal expenses before deductibility is determined.
    September 17, 2026   Case Laws Income Tax
    Enhanced taxation under section 115BBE applies to surrendered excess stock and cash where the amended provision was already operative.
    September 17, 2026   Case Laws Benami Property
    Statutory sequence for benami attachment invalidates approval obtained before notice to the alleged benamidar, requiring fresh action under law.
    September 17, 2026   Case Laws Customs
    Writ jurisdiction over customs prohibition claims survives alternative remedies where statutory basis and objective legal standards are disputed.
    September 17, 2026   Case Laws Customs
    Statutory limits on provisional attachment require bank accounts to be defrozen when the permitted attachment period expires.
    September 17, 2026   Case Laws Customs
    Transitional protection for restricted gold imports can cover genuine prepaid contracts despite absence of irrevocable commercial letters of credit.
    September 17, 2026   Case Laws Customs
    Reasonable belief for gold seizure governs statutory burden, confiscation, and penalties where smuggling lacks evidentiary support.
    September 17, 2026   Case Laws Customs
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September 17, 2026   Case Laws Income Tax
Functional comparability under TNMM supports cross-industry distributor benchmarks for licence fees when FAR profiles align.
September 17, 2026   Case Laws Income Tax
Interest in an enforced foreign arbitral award becomes judgment debt and falls outside Indian income taxation.
September 17, 2026   Case Laws Income Tax
Penalty limitation under section 275(1)(c) runs from the show-cause notice where proceedings arise outside assessment proceedings.
September 17, 2026   Case Laws Income Tax
Banking tax treatment clarifies real-income recognition, securities valuation, bad-debt provisions and employee-benefit deductions across assessment issues.
September 17, 2026   Case Laws Income Tax
Maximum marginal rate cannot govern public charitable association income assessed at normal Association of Persons rates.
September 17, 2026   Case Laws Income Tax
Rental income valuation requires credible local comparables; family-business salary and commercially expedient unsecured-loan interest remained deductible.
September 17, 2026   Case Laws Income Tax
Service permanent establishment requirements exclude remote cost-to-cost reimbursements from Indian tax where no personnel are physically present.
September 17, 2026   Case Laws Income Tax
Section 263 revision requires a genuine assessment error; unchecked borrowed-fund use warranted fresh interest-capitalisation examination.
September 17, 2026   Case Laws Income Tax
Tonnage tax shipping income excludes non-core receipts, while commercially expedient maritime sponsorship remains deductible business expenditure.
September 17, 2026   Case Laws Income Tax
Limitation for final assessment requires timely completion after time-barred DRP objections; otherwise, the assessment is void.
September 17, 2026   Case Laws Income Tax
Proof of cash receipt is essential before imposing penalties for alleged violations of cash-transaction restrictions.
September 17, 2026   Case Laws Income Tax
Foreign-contribution disclosure mismatches require substantive reconciliation, preventing automatic treatment of separately reported interest income as undisclosed income.
September 17, 2026   Case Laws Income Tax
Business expenditure after branch transfer requires verification of retained assets and related legal expenses before deductibility is determined.
September 17, 2026   Case Laws Income Tax
Enhanced taxation under section 115BBE applies to surrendered excess stock and cash where the amended provision was already operative.
September 17, 2026   Case Laws Benami Property
Statutory sequence for benami attachment invalidates approval obtained before notice to the alleged benamidar, requiring fresh action under law.
September 17, 2026   Case Laws Customs
Writ jurisdiction over customs prohibition claims survives alternative remedies where statutory basis and objective legal standards are disputed.
September 17, 2026   Case Laws Customs
Statutory limits on provisional attachment require bank accounts to be defrozen when the permitted attachment period expires.
September 17, 2026   Case Laws Customs
Transitional protection for restricted gold imports can cover genuine prepaid contracts despite absence of irrevocable commercial letters of credit.
September 17, 2026   Case Laws Customs
Reasonable belief for gold seizure governs statutory burden, confiscation, and penalties where smuggling lacks evidentiary support.
September 17, 2026   Case Laws Customs
Strict construction of customs exemptions denied concession for brake components, while limitation restricted differential duty to timely Bills of Entry.

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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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