Capital Gain Deductibility: proportionate IPO and PMS expenses held allowable against capital gains where netting and nexus to transfer are establishe...
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Finality barred reopening of transfers and acquisitions already examined by a court-approved SIT; later foreign material, media reports and digital fragments were treated as insufficient grounds for fresh investigation, prosecution or coercive action. The Court also noted that zoological acquisitions supported by valid domestic permission and CITES compliance may not be invalidated merely because the foreign source was described as commercial, with the purpose code issue not being decisive except for Appendix I specimens. Requests to compel insiders while insulating them from confidentiality consequences were rejected. Prospectively, the Court directed the CITES Management Authority of India to strengthen import-permit due diligence through liaison with the CITES Secretariat and an SOP for Appendix I imports.
Finality barred reopening of transfers and acquisitions already examined by a court-approved SIT; later foreign material, media reports and digital fragments were treated as insufficient grounds for fresh investigation, prosecution or coercive action. The Court also noted that zoological acquisitions supported by valid domestic permission and CITES compliance may not be invalidated merely because the foreign source was described as commercial, with the purpose code issue not being decisive except for Appendix I specimens. Requests to compel insiders while insulating them from confidentiality consequences were rejected. Prospectively, the Court directed the CITES Management Authority of India to strengthen import-permit due diligence through liaison with the CITES Secretariat and an SOP for Appendix I imports.
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