https://www.taxtmi.com/caselaws?id=354152 An unregistered shareholders' agreement and related arrangements could not trigger deemed transfer under section 2(47)(v) after the 2001 Registration Act amendment, because an unregistered instrument cannot support section 53A protection; income also could not accrue without an enforceable right to receive it. On the project receipts, only the interest component was taxable, while specified expenses were excluded and the balance retained capital-receipt character. Interest on fully convertible debentures was treated as work-in-progress on a revenue-neutral basis, repayment of an existing debt was not hit by section 40A(3), and current-account movements were not deemed dividends under section 2(22)(e). en-us Fri, 12 Jan 2018 00:00:00 +0530 Tue, 30 Jun 2026 16:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=354152 An unregistered shareholders' agreement and related arrangements could not trigger deemed transfer under section 2(47)(v) after the 2001 Registration Act amendment, because an unregistered instrument cannot support section 53A protection; income also could not accrue without an enforceable right to receive it. On the project receipts, only the interest component was taxable, while specified expenses were excluded and the balance retained capital-receipt character. Interest on fully convertible debentures was treated as work-in-progress on a revenue-neutral basis, repayment of an existing debt was not hit by section 40A(3), and current-account movements were not deemed dividends under section 2(22)(e). Case-Laws Income Tax Fri, 12 Jan 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=354152