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...
Characterization of receipts - transfer of shares - Business income or capital gains - CIT(A) did not go deep into the part of the consideration relatable to transfer of shares. He simply applied the magic wand and held that 10% of the consideration was towards non-compete and termination of role of the assessee in management. - the exercise of attributing sale consideration to the shares and the negative covenants is required to be done afresh by the AO. - AT
Characterization of receipts - transfer of shares - Business income or capital gains - CIT(A) did not go deep into the part of the consideration relatable to transfer of shares. He simply applied the magic wand and held that 10% of the consideration was towards non-compete and termination of role of the assessee in management. - the exercise of attributing sale consideration to the shares and the negative covenants is required to be done afresh by the AO. - AT
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