Separate speaking orders on reopening objections are mandatory; deciding them within reassessment invalidates jurisdiction and precludes revival of st...
Compulsorily convertible debentures remain debt before conversion, preventing transfer-pricing and interest-deduction disallowances on the stated fact...
Stock-in-trade transfer taxability follows possession and consideration, not later conveyance registration, limiting deemed-value provisions to the ac...
Section 10(23C) exemption for the relevant year did not require return filing by entities outside the categories expressly covered by the Twentieth Proviso. A later amendment imposing a return-filing condition for specified entities could not be applied to that year. Where the revenue authorities did not find that the substantive exemption conditions were unmet, non-filing of a return alone could not defeat the claim. Exemption was consequently directed to be granted in accordance with law, and the income assessed under "Income from Other Sources" was deleted.
Section 10(23C) exemption for the relevant year did not require return filing by entities outside the categories expressly covered by the Twentieth Proviso. A later amendment imposing a return-filing condition for specified entities could not be applied to that year. Where the revenue authorities did not find that the substantive exemption conditions were unmet, non-filing of a return alone could not defeat the claim. Exemption was consequently directed to be granted in accordance with law, and the income assessed under "Income from Other Sources" was deleted.
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TaxTMI 
TaxTMI 
of 4891 
