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...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Section 48 requires capital gains to be computed using the consideration actually received or accruing, unless an applicable deeming provision permits substitution with fair market value. Redemption proceeds from non-cumulative preference shares therefore cannot be replaced by the price of equity shares in the same company, because the share classes carry different rights and no additional consideration was established. The provision for unquoted-share transfers and the rule for unascertainable consideration do not apply where redemption consideration is ascertainable. A claim for enhanced acquisition cost following capital reduction and consolidation requires factual verification of acquisition records, share identity, legal effect and cost allocation; it cannot be raised as a pure legal ground without an existing factual record.
Section 48 requires capital gains to be computed using the consideration actually received or accruing, unless an applicable deeming provision permits substitution with fair market value. Redemption proceeds from non-cumulative preference shares therefore cannot be replaced by the price of equity shares in the same company, because the share classes carry different rights and no additional consideration was established. The provision for unquoted-share transfers and the rule for unascertainable consideration do not apply where redemption consideration is ascertainable. A claim for enhanced acquisition cost following capital reduction and consolidation requires factual verification of acquisition records, share identity, legal effect and cost allocation; it cannot be raised as a pure legal ground without an existing factual record.
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