International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
Transaction value between related persons requires market-equivalent pricing; importer must prove declared value mirrors ordinary international trade ...
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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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