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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Reassessment for unexplained investment in immovable property may be initiated where the income-tax return was only processed and material indicates that the investment, including an unexplained cash component, was disproportionate to disclosed income. Disclosure of the property purchase in a wealth-tax return does not by itself establish disclosure in the income-tax return of material facts concerning the source of funds or the transaction's true nature. Explanation 2(b) to section 147 may therefore apply. The assessing officer is not deemed to have considered information contained only in the wealth-tax return. Sanction under section 151 is satisfied where the approving authority records satisfaction on the assessing officer's recorded reasons.
Reassessment for unexplained investment in immovable property may be initiated where the income-tax return was only processed and material indicates that the investment, including an unexplained cash component, was disproportionate to disclosed income. Disclosure of the property purchase in a wealth-tax return does not by itself establish disclosure in the income-tax return of material facts concerning the source of funds or the transaction's true nature. Explanation 2(b) to section 147 may therefore apply. The assessing officer is not deemed to have considered information contained only in the wealth-tax return. Sanction under section 151 is satisfied where the approving authority records satisfaction on the assessing officer's recorded reasons.
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