Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Melting and converting imported bullion into bars, coins, medals and gift items on job-work basis was treated as manufacture because the process produced goods with a distinct character and use. Extended limitation and penalty were rejected because the dispute turned on classification and interpretation, transactions were accounted for, and no intent to evade duty was shown. Gold bars and imported bullion were classified as primary gold under Heading 7108 and held exempt, and branded gold and silver coins made from duty-paid metal were also exempt; medals, medallions and gift items remained dutiable at 1% for the normal period only, while Rule 12AA was held inapplicable.
Melting and converting imported bullion into bars, coins, medals and gift items on job-work basis was treated as manufacture because the process produced goods with a distinct character and use. Extended limitation and penalty were rejected because the dispute turned on classification and interpretation, transactions were accounted for, and no intent to evade duty was shown. Gold bars and imported bullion were classified as primary gold under Heading 7108 and held exempt, and branded gold and silver coins made from duty-paid metal were also exempt; medals, medallions and gift items remained dutiable at 1% for the normal period only, while Rule 12AA was held inapplicable.
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