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...
Public servant status under anti-corruption law extends to recognised stock exchange leadership; constitutional and sanction challenges do not succeed...
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For share-premium taxation of unquoted shares, a chartered accountant's valuation report supported by detailed workings may not be rejected merely on suspicion or without examining its underlying material. The notes state that an Assessing Officer's independent net asset value calculation was not sustainable where the officer lacked valuation expertise and had not addressed the submitted report, resulting in deletion of the excess share-premium addition. They also explain that, in a limited-scrutiny assessment restricted to advances, loans and share premium, expenditure disallowance falls outside jurisdiction unless recorded satisfaction and prior approval permit conversion to complete scrutiny. The expenditure disallowance was therefore deleted, and the Revenue's appeal was dismissed.
For share-premium taxation of unquoted shares, a chartered accountant's valuation report supported by detailed workings may not be rejected merely on suspicion or without examining its underlying material. The notes state that an Assessing Officer's independent net asset value calculation was not sustainable where the officer lacked valuation expertise and had not addressed the submitted report, resulting in deletion of the excess share-premium addition. They also explain that, in a limited-scrutiny assessment restricted to advances, loans and share premium, expenditure disallowance falls outside jurisdiction unless recorded satisfaction and prior approval permit conversion to complete scrutiny. The expenditure disallowance was therefore deleted, and the Revenue's appeal was dismissed.
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