Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Section 153C jurisdiction is treated as constructively satisfied where the same Assessing Officer handles the searched person and the other person, so physical handover of seized material is not essential once the officer applies his mind. One consolidated satisfaction note can cover the six-year block under sections 153C and 153A, and an Investigation Wing trigger is not fatal by itself. On limitation, the assessments were time-barred because the relevant date, whether taken as the search, constructive handover, conclusion of Settlement Commission proceedings, or recording of satisfaction, placed the proceedings outside the statutory period. Additions based on uncorroborated third-party excel sheets were unsustainable where identity was doubtful and cross-examination was denied.
Section 153C jurisdiction is treated as constructively satisfied where the same Assessing Officer handles the searched person and the other person, so physical handover of seized material is not essential once the officer applies his mind. One consolidated satisfaction note can cover the six-year block under sections 153C and 153A, and an Investigation Wing trigger is not fatal by itself. On limitation, the assessments were time-barred because the relevant date, whether taken as the search, constructive handover, conclusion of Settlement Commission proceedings, or recording of satisfaction, placed the proceedings outside the statutory period. Additions based on uncorroborated third-party excel sheets were unsustainable where identity was doubtful and cross-examination was denied.
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