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 assessment u/s 153C - Period of limitation - Assessment of income of any other person in search proceedings - The proviso in Section 153C(1) includes not only the question of abatement but also determines the date from which the six-year limitation period should be calculated. - The High court analyzed the relevant legal provisions and case law, emphasizing the need to prevent prejudice to affected parties due to delayed proceedings. It concluded that the assessment orders were indeed barred by limitation, highlighting the unjustified delay in recording satisfaction. Considering the statutory limitation period and lapse of time for completing the assessment, the court quashed the assessment orders.
Validity of assessment u/s 153C - Period of limitation - Assessment of income of any other person in search proceedings - The proviso in Section 153C(1) includes not only the question of abatement but also determines the date from which the six-year limitation period should be calculated. - The High court analyzed the relevant legal provisions and case law, emphasizing the need to prevent prejudice to affected parties due to delayed proceedings. It concluded that the assessment orders were indeed barred by limitation, highlighting the unjustified delay in recording satisfaction. Considering the statutory limitation period and lapse of time for completing the assessment, the court quashed the assessment orders.
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