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    Section 47(xiii) succession remains exempt despite pre-conversion capital withdrawals, while section 153A fails without incriminating material.
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Clinical Research Organisations performing sponsor-approved...

Clinical trial testing exemption covers sponsor-approved CRO services; employee bond forfeitures are not taxable training consideration.

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Service Tax September 7, 2026 Case Laws AT
Clinical Research Organisations performing sponsor-approved clinical trials qualify for service-tax exemption on technical testing and analysis of newly developed drugs, even though regulatory approval is issued to the sponsor rather than separately to the CRO. Employee bond deposits forfeited on premature resignation are compensation for breach of an employment undertaking, not consideration for commercial training or coaching or for tolerating an act. Extended limitation requires deliberate suppression or other specified conduct with intent to evade tax; prior departmental disclosures and a tenable belief in exemption negate that requirement. Consequently, the technical-testing and training-related demands fail, with the latter also time-barred. Interest and penalties cannot survive where no principal tax demand or intent to evade is established.

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Acts Income Tax