Compulsorily convertible debentures remain debt before conversion, preventing transfer-pricing and interest-deduction disallowances on the stated fact...
Stock-in-trade transfer taxability follows possession and consideration, not later conveyance registration, limiting deemed-value provisions to the ac...
Alternative statutory remedy under GST bars writ challenge where classification, notice variance, and hearing disputes require factual appellate revie...
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Termination compensation under a distribution arrangement that is substantively an agency relationship is treated as business income rather than a capital receipt, and taxation is confined to the settlement actually received. A non-compete covenant integral to acquiring and protecting a trademark qualifies as a depreciable intangible asset. For section 80-IB, only costs directly connected with an eligible undertaking should reduce its profit; allocation of finance, research, travel, head-office and export-promotion costs depends on factual nexus. Section 80HHC excludes receipts lacking a direct export nexus, while concurrent 80-IB and 80HHC deductions remain subject to the gross-total-income ceiling. A purely legal additional ground based on the existing record may be considered.
Termination compensation under a distribution arrangement that is substantively an agency relationship is treated as business income rather than a capital receipt, and taxation is confined to the settlement actually received. A non-compete covenant integral to acquiring and protecting a trademark qualifies as a depreciable intangible asset. For section 80-IB, only costs directly connected with an eligible undertaking should reduce its profit; allocation of finance, research, travel, head-office and export-promotion costs depends on factual nexus. Section 80HHC excludes receipts lacking a direct export nexus, while concurrent 80-IB and 80HHC deductions remain subject to the gross-total-income ceiling. A purely legal additional ground based on the existing record may be considered.
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