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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...
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Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Limitation for penalties arising from alleged cash receipts contrary to section 269ST remains subject to differing views on when the limitation period under section 275(1)(c) begins. Under either approach, penalty proceedings under section 271DA were time-barred because the assessment orders were passed in March 2024, the six-month period ended on 30 September 2024, and the show-cause notice was issued later. The penalty orders and consequential demand notices were therefore unsustainable, and the appeals were dismissed.
Limitation for penalties arising from alleged cash receipts contrary to section 269ST remains subject to differing views on when the limitation period under section 275(1)(c) begins. Under either approach, penalty proceedings under section 271DA were time-barred because the assessment orders were passed in March 2024, the six-month period ended on 30 September 2024, and the show-cause notice was issued later. The penalty orders and consequential demand notices were therefore unsustainable, and the appeals were dismissed.
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