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...
Capital gains on transfer of TDR/FSI credit may not arise where the applicable law provides no ascertainable cost of acquisition and the computation mechanism therefore fails. The charging and computation provisions operate as an integrated code, consistent with the principle in CIT v. B.C. Srinivasa Setty. TDR/DRC granted under development regulations in lieu of compensation was treated as a statutory entitlement acquired without monetary expenditure, whose value remained indeterminate until utilisation. The pre-amendment deeming provision did not cover such rights, while the later inclusion of other intangible assets and rights applied only from A.Y. 2024-25 and could not retrospectively cure the gap. The land and TDR were distinct assets, so the land's value could not be treated as the TDR's cost. The reported additions for A.Y. 2016-17 were deleted.
Capital gains on transfer of TDR/FSI credit may not arise where the applicable law provides no ascertainable cost of acquisition and the computation mechanism therefore fails. The charging and computation provisions operate as an integrated code, consistent with the principle in CIT v. B.C. Srinivasa Setty. TDR/DRC granted under development regulations in lieu of compensation was treated as a statutory entitlement acquired without monetary expenditure, whose value remained indeterminate until utilisation. The pre-amendment deeming provision did not cover such rights, while the later inclusion of other intangible assets and rights applied only from A.Y. 2024-25 and could not retrospectively cure the gap. The land and TDR were distinct assets, so the land's value could not be treated as the TDR's cost. The reported additions for A.Y. 2016-17 were deleted.
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