Alternative statutory remedy under GST bars writ challenge where classification, notice variance, and hearing disputes require factual appellate revie...
Duplicate PAN cancellation timeframe requires prior administrative representation before judicial intervention, ensuring a time-bound decision on the ...
Natural justice and pre-CIRP labour awards protect termination compensation, permitting withdrawal of court deposits despite later insolvency resoluti...
Arbitration of SEZ sub-lease monetary claims preserves rent, maintenance, termination, improvements and damages disputes while unused premises are vac...
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Compulsorily convertible debentures remain debt until conversion, notwithstanding mandatory conversion, absence of principal repayment, regulatory classification or accounting treatment. Their interest must therefore be benchmarked as debt for arm's-length pricing; treating pre-conversion CCDs as equity and fixing interest at nil is unsustainable. Debt-equity recharacterisation is contemplated under Chapter X-A only where an arrangement is declared impermissible and the prescribed procedure is followed. As that procedure was not invoked, the transfer-pricing adjustment based on recharacterisation of unsecured CCDs as equity was deleted.
Compulsorily convertible debentures remain debt until conversion, notwithstanding mandatory conversion, absence of principal repayment, regulatory classification or accounting treatment. Their interest must therefore be benchmarked as debt for arm's-length pricing; treating pre-conversion CCDs as equity and fixing interest at nil is unsustainable. Debt-equity recharacterisation is contemplated under Chapter X-A only where an arrangement is declared impermissible and the prescribed procedure is followed. As that procedure was not invoked, the transfer-pricing adjustment based on recharacterisation of unsecured CCDs as equity was deleted.
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