Preferential tariff claims under trade agreements require agreement-consistent origin checks, with safeguards against automatic denial for subsequent ...
Suppressed outward supplies require transaction-wise verification and reasoned findings before diary entries can support tax and penalty determination...
Succession of a firm by a company satisfies section 47(xiii) where all assets and liabilities immediately before succession vest in the company and partners receive only company shares. Pre-succession capital withdrawals, asset sales and changes in partners' profit-sharing ratios do not, absent a statutory restriction, disqualify the succession or make it a taxable transfer. Search-assessment proceedings require incriminating material: routine board resolutions, no-objection certificates, legal notes, valuation reports and firm-constitution records generated in ordinary business are not incriminating. In their absence, assessment under section 153A is not maintainable, and the departmental appeal was dismissed.
Succession of a firm by a company satisfies section 47(xiii) where all assets and liabilities immediately before succession vest in the company and partners receive only company shares. Pre-succession capital withdrawals, asset sales and changes in partners' profit-sharing ratios do not, absent a statutory restriction, disqualify the succession or make it a taxable transfer. Search-assessment proceedings require incriminating material: routine board resolutions, no-objection certificates, legal notes, valuation reports and firm-constitution records generated in ordinary business are not incriminating. In their absence, assessment under section 153A is not maintainable, and the departmental appeal was dismissed.
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