Co-operative society's mandatory reserve and share capital fixed deposits with banks-interest treated as business income under 80P(2)(a)(iii) deductio...
Income tax reassessment reopening after four years on investigation tip, without s.147 proviso disclosure failure, struck down as borrowed satisfactio...
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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