Tariff classification of vehicle gear components follows the specific gearing entry, displacing motor-vehicle parts classification and related liabili...
Necessary-party requirements limit impleadment of independent entities, while deferred consideration does not create an appealable adverse determinati...
Food supplement classification requires common parlance and authoritative tests, preventing treatment as proprietary Ayurvedic medicines without suppo...
Specified regulatory authority income receives conditional tax exemption, subject to non-commercial activity, unchanged income character, and return f...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return-filing...
Section 56(2)(vii)(c) is discussed as applying where shares or securities are received from another person for inadequate consideration. The notes distinguish a fresh allotment from a transfer of existing property: newly issued shares arise from unissued share capital and do not pre-exist as property transferred by another person. On a strict construction of the deeming provision, the term "receives" is treated as requiring prior existence of the property. The discussion records that the provision was considered inapplicable to fresh share allotments, resulting in deletion of the related additions; the Revenue's challenge based on a sibling's earlier case was treated as academic.
Section 56(2)(vii)(c) is discussed as applying where shares or securities are received from another person for inadequate consideration. The notes distinguish a fresh allotment from a transfer of existing property: newly issued shares arise from unissued share capital and do not pre-exist as property transferred by another person. On a strict construction of the deeming provision, the term "receives" is treated as requiring prior existence of the property. The discussion records that the provision was considered inapplicable to fresh share allotments, resulting in deletion of the related additions; the Revenue's challenge based on a sibling's earlier case was treated as academic.
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