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...
Section 56(2)(viib) does not apply where shares are issued as non-cash consideration for acquiring a business undertaking, because no money is received; the share-premium addition was deleted. Bad-debt deductions were allowed where receivables had been taxed earlier and were written off, including student-fee receivables supported by detailed records. Section 14A disallowance was deleted in the absence of exempt income. Reversal of advance or unearned fees did not attract sections 41(1) or 28(iv) where no earlier deduction or benefit arose, and acknowledged creditor liabilities were not treated as ceased. Loan processing charges were allowable as interest-related business expenditure. TDS-related relief depended on the payee offering income to tax; other disallowances were sustained, restricted, or remanded according to the applicable rules and evidence of liability crystallisation.
Section 56(2)(viib) does not apply where shares are issued as non-cash consideration for acquiring a business undertaking, because no money is received; the share-premium addition was deleted. Bad-debt deductions were allowed where receivables had been taxed earlier and were written off, including student-fee receivables supported by detailed records. Section 14A disallowance was deleted in the absence of exempt income. Reversal of advance or unearned fees did not attract sections 41(1) or 28(iv) where no earlier deduction or benefit arose, and acknowledged creditor liabilities were not treated as ceased. Loan processing charges were allowable as interest-related business expenditure. TDS-related relief depended on the payee offering income to tax; other disallowances were sustained, restricted, or remanded according to the applicable rules and evidence of liability crystallisation.
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