Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
Statutory associate-company criteria governed whether the group company required consolidation and related-party disclosures. The Tribunal majority found no prescribed voting threshold, agreement, control, or participation in business decisions; accounting standards could supplement but not override the statutory definition. Consolidation and related-party disclosure contraventions therefore failed. The majority also found the real-estate bulk-sale memoranda and underlying projects genuine, with no proof that common personnel, funding arrangements, accounting differences, or weak finances established a sham scheme, market impact, unlawful gain, or PFUTP violation. Securities-enforcement proceedings were further initiated after inordinate, unexplained delay following completed transactions. The appeals succeeded, penalties were set aside and refundable; the Presiding Officer dissented.
Statutory associate-company criteria governed whether the group company required consolidation and related-party disclosures. The Tribunal majority found no prescribed voting threshold, agreement, control, or participation in business decisions; accounting standards could supplement but not override the statutory definition. Consolidation and related-party disclosure contraventions therefore failed. The majority also found the real-estate bulk-sale memoranda and underlying projects genuine, with no proof that common personnel, funding arrangements, accounting differences, or weak finances established a sham scheme, market impact, unlawful gain, or PFUTP violation. Securities-enforcement proceedings were further initiated after inordinate, unexplained delay following completed transactions. The appeals succeeded, penalties were set aside and refundable; the Presiding Officer dissented.
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