Capital Gain Deductibility: proportionate IPO and PMS expenses held allowable against capital gains where netting and nexus to transfer are establishe...
Admissibility of Documentary Evidence: appellate authority may admit self explanatory documents on first production and uphold deletion of unexplained...
The note addresses VCES eligibility where pre- and post-July 2012 liability arise from different legal questions: whether the appellant rendered an intellectual property service before July 2012 versus whether permitting Hallmarking/Assaying Centres to administer the BIS scheme for royalty constituted a 'service' after July 2012 under the post-July 2012 definition. It concludes that the issues are distinct, so the identical-issue proviso to the VCES does not bar acceptance of the later declaration; reliance on prior notices about intellectual property services did not preclude voluntary compliance for the separate charge based on the broader post-July 2012 service definition.
The note addresses VCES eligibility where pre- and post-July 2012 liability arise from different legal questions: whether the appellant rendered an intellectual property service before July 2012 versus whether permitting Hallmarking/Assaying Centres to administer the BIS scheme for royalty constituted a 'service' after July 2012 under the post-July 2012 definition. It concludes that the issues are distinct, so the identical-issue proviso to the VCES does not bar acceptance of the later declaration; reliance on prior notices about intellectual property services did not preclude voluntary compliance for the separate charge based on the broader post-July 2012 service definition.
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