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...
Reopening of assessment - reasons for re-opening within or beyond 4 years - reasons to believe - The court specifically pointed out that the information used from the DRI and the Shah Commission reports was not adequately scrutinized independently by the assessing officers to form a reasonable belief of tax evasion. The court noted that the decision of the Supreme Court, which found mining leases post-2007 to be illegal, could not retroactively make previous business activities illegal for tax purposes. The court emphasized that such interpretations were not known or could not have been known by the taxpayers at the time of filing their returns.
Reopening of assessment - reasons for re-opening within or beyond 4 years - reasons to believe - The court specifically pointed out that the information used from the DRI and the Shah Commission reports was not adequately scrutinized independently by the assessing officers to form a reasonable belief of tax evasion. The court noted that the decision of the Supreme Court, which found mining leases post-2007 to be illegal, could not retroactively make previous business activities illegal for tax purposes. The court emphasized that such interpretations were not known or could not have been known by the taxpayers at the time of filing their returns.
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