Business expenditure and depreciation rules allow operational outgoings while limiting disallowances for personal elements and unsupported third-party...
Compromise-and-arrangement extensions may accommodate debt assignment where creditor commercial judgment supports value maximisation and avoids proced...
Delayed-payment surcharge is not taxable tolerance consideration where it penalises default, while meter testing follows electricity distribution trea...
Sufficient cause for delayed revenue income-tax appeals requires bona fides, due diligence and a credible explanation; otherwise limitation bars appea...
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.
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
