Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
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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