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...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Validity of Reopening of assessment u/s 147 - The order of learned Judge suggesting that the question of whether there was true and full disclosure is still open, again appears to us to be misdirected / misplaced since while setting out the reasons for reassessment, the respondent has not even remotely suggested that there was no full and true disclosure on the part of the appellant. Thus it appears the order of the learned Single Judge is an improvement of the assessment proceeding which is quasijudicial in nature and thus impermissible. - HC
Validity of Reopening of assessment u/s 147 - The order of learned Judge suggesting that the question of whether there was true and full disclosure is still open, again appears to us to be misdirected / misplaced since while setting out the reasons for reassessment, the respondent has not even remotely suggested that there was no full and true disclosure on the part of the appellant. Thus it appears the order of the learned Single Judge is an improvement of the assessment proceeding which is quasijudicial in nature and thus impermissible. - HC
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