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...
Reopening of assessment u/s 147 - re-assessment proceedings have been initiated beyond a period of four years - there has been full disclosure by the assessee in relation to the issues flagged in the reasons for re-assessment and the Department has not in this case discharged the statutory burden as set out in the proviso to Section 147. The impugned proceedings are held to be barred by limitation and the impugned orders are quashed. - HC
Reopening of assessment u/s 147 - re-assessment proceedings have been initiated beyond a period of four years - there has been full disclosure by the assessee in relation to the issues flagged in the reasons for re-assessment and the Department has not in this case discharged the statutory burden as set out in the proviso to Section 147. The impugned proceedings are held to be barred by limitation and the impugned orders are quashed. - HC
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