Commercial vehicle depreciation, scientifically determined warranty provisions and exempt-income disallowances were resolved in favour of the taxpayer...
Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
Capital-goods exemption covers plant-modernisation accessories, while the import restriction applies only to earlier capital-goods components and spar...
Constitutional judicial review permits challenges to ECIRs and connected money-laundering proceedings where coercive action affects fundamental intere...
Compulsory-acquisition compensation attributable to development rights transferred under a pre-existing development agreement is discussed as not accruing to the land-holding company where the developer held exclusive commercial rights, funded the acquisition, and bore development risks. The notes distinguish an overriding contractual obligation from an application of income after accrual. They further state that taxing the same transferred compensation again in the land-holder's hands, after its taxation in the developer's hands, would create impermissible double taxation without statutory authority. Consistent treatment is also identified as relevant where materially identical development arrangements have received different tax treatment.
Compulsory-acquisition compensation attributable to development rights transferred under a pre-existing development agreement is discussed as not accruing to the land-holding company where the developer held exclusive commercial rights, funded the acquisition, and bore development risks. The notes distinguish an overriding contractual obligation from an application of income after accrual. They further state that taxing the same transferred compensation again in the land-holder's hands, after its taxation in the developer's hands, would create impermissible double taxation without statutory authority. Consistent treatment is also identified as relevant where materially identical development arrangements have received different tax treatment.
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