Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Eligibility for exemption depends on strict construction of the product description; reapers without binder are ineligible, but confiscation and penal...
The article examines denial of trust exemption where purchases of shares from specified persons may trigger prohibition; it explains that the prohibition applies only if the trust purchased shares directly from persons who held a substantial interest (defined by control of about 20% voting power) or through entities controlled by them. The tribunal found sellers did not possess such substantial interest or control, noted the Assessing Officer conflated distinct provisions, and concluded the prohibition was inapplicable; the appeal by the trust was allowed.
The article examines denial of trust exemption where purchases of shares from specified persons may trigger prohibition; it explains that the prohibition applies only if the trust purchased shares directly from persons who held a substantial interest (defined by control of about 20% voting power) or through entities controlled by them. The tribunal found sellers did not possess such substantial interest or control, noted the Assessing Officer conflated distinct provisions, and concluded the prohibition was inapplicable; the appeal by the trust was allowed.
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