Permanent establishment tests: independent subsidiary premises and principal-to-principal dealings did not create Indian taxability for offshore suppl...
Valuation Officer estimates govern property-value additions once statutory valuation is invoked, requiring fresh consideration of objections and compa...
Waiver of written show-cause notice may prevent a later procedural challenge after participation in customs adjudication, preserving statutory appella...
Retrospective invalidity of ocean-freight IGST supports refunds despite non-party status and prior credit utilisation, subject to authorised appeal gr...
Additional evidence in departmental appeals may include show-cause-notice material without introducing a new case where it merely corroborates existin...
Reasoned rectification orders require consideration of expenditure disclosed in income-tax returns, preventing revision based on incomplete income com...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
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Compulsorily convertible debentures do not warrant a nil arm's length price for pre-conversion coupon interest merely because conversion is mandatory and cash redemption is unavailable. Recharacterisation of debt requires contractual and economic facts showing divergence between form and substance or commercial irrationality, and a nil return must be supported by a prescribed transfer-pricing method and uncontrolled comparables. The nil transfer-pricing adjustment was deleted, while the proposed domestic benchmark remained subject to scrutiny. The related interest disallowance was set aside pending verification of capitalisation, business use and interest-limitation treatment, without double deduction or double disallowance. Consequential statutory interest or fees must identify the charging provision, period and calculation; a penalty challenge remains premature before a penalty order.
Compulsorily convertible debentures do not warrant a nil arm's length price for pre-conversion coupon interest merely because conversion is mandatory and cash redemption is unavailable. Recharacterisation of debt requires contractual and economic facts showing divergence between form and substance or commercial irrationality, and a nil return must be supported by a prescribed transfer-pricing method and uncontrolled comparables. The nil transfer-pricing adjustment was deleted, while the proposed domestic benchmark remained subject to scrutiny. The related interest disallowance was set aside pending verification of capitalisation, business use and interest-limitation treatment, without double deduction or double disallowance. Consequential statutory interest or fees must identify the charging provision, period and calculation; a penalty challenge remains premature before a penalty order.
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