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...
Alleged bogus purchases could not justify an ad hoc gross profit addition where the suppliers' non-filing of returns was the only adverse feature, the purchases were recorded in the books, and no contrary material disproved them; the gross profit-based addition was deleted. On alleged unaccounted sales, only the profit element could be taxed, so the Tribunal sustained addition at a net profit rate of 4% rather than taxing the full sale proceeds. Cash entry-fee receipts were extrapolated from a short period, so the addition was restricted to 25%. Separate unexplained expenditure was telescoped against the estimated undisclosed income and deleted, and section 69C could not apply to recorded purchases paid through banking channels.
Alleged bogus purchases could not justify an ad hoc gross profit addition where the suppliers' non-filing of returns was the only adverse feature, the purchases were recorded in the books, and no contrary material disproved them; the gross profit-based addition was deleted. On alleged unaccounted sales, only the profit element could be taxed, so the Tribunal sustained addition at a net profit rate of 4% rather than taxing the full sale proceeds. Cash entry-fee receipts were extrapolated from a short period, so the addition was restricted to 25%. Separate unexplained expenditure was telescoped against the estimated undisclosed income and deleted, and section 69C could not apply to recorded purchases paid through banking channels.
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