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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...
The HC held that the petitioner, having subsequently filed requisite returns and paid assessed tax following issuance of best-judgment assessment orders under s.62(1) of the UPGST Act, benefited from the deeming fiction in s.62(2) so that further demands were required to be withdrawn. Creation of liens and freezing of the petitioner's bank accounts under s.79 more than a year after taxes were paid was held impermissible as applied in the circumstances and constituted an unduly harsh exercise of recovery powers; invocation of s.79 for recovery was therefore ultra vires as to these amounts. The petition was allowed and disposed of.
The HC held that the petitioner, having subsequently filed requisite returns and paid assessed tax following issuance of best-judgment assessment orders under s.62(1) of the UPGST Act, benefited from the deeming fiction in s.62(2) so that further demands were required to be withdrawn. Creation of liens and freezing of the petitioner's bank accounts under s.79 more than a year after taxes were paid was held impermissible as applied in the circumstances and constituted an unduly harsh exercise of recovery powers; invocation of s.79 for recovery was therefore ultra vires as to these amounts. The petition was allowed and disposed of.
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