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...
Transfer under a joint development agreement requires more than execution of development documents and an irrevocable power of attorney: property rights must be effectively and irrevocably parted with through an enforceable arrangement. The notes state that a later partition decree and development agreement may show that no completed transfer or real income accrued. They further explain that agricultural income from inherited land should not be rejected solely for missing old cultivation records where later records support agricultural use, the land's character is undisputed, and prior assessments accepted the claim without changed facts. A search-based addition founded only on another person's statement and ad hoc allocation requires corroborative material linking undisclosed income to the assessee.
Transfer under a joint development agreement requires more than execution of development documents and an irrevocable power of attorney: property rights must be effectively and irrevocably parted with through an enforceable arrangement. The notes state that a later partition decree and development agreement may show that no completed transfer or real income accrued. They further explain that agricultural income from inherited land should not be rejected solely for missing old cultivation records where later records support agricultural use, the land's character is undisputed, and prior assessments accepted the claim without changed facts. A search-based addition founded only on another person's statement and ad hoc allocation requires corroborative material linking undisclosed income to the assessee.
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