Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
Reduction of share capital under Section 66 was examined for jurisdictional defects in appellate bench composition, procedural sufficiency of the statutory notice and disclosures, independence of the valuer, and the permissibility of applying a discount for lack of marketability (DLOM). The Court found no jurisdictional defect in the tribunal's bench composition and declined to disturb the tribunal orders. It held Section 66 does not require inclusion of a valuation report in the notice where the offered price and reports are available for inspection, rejected a claim of demonstrable valuer bias, and accepted that DLOM and the valuation were not manifestly unreasonable, so the reduction stands.
Reduction of share capital under Section 66 was examined for jurisdictional defects in appellate bench composition, procedural sufficiency of the statutory notice and disclosures, independence of the valuer, and the permissibility of applying a discount for lack of marketability (DLOM). The Court found no jurisdictional defect in the tribunal's bench composition and declined to disturb the tribunal orders. It held Section 66 does not require inclusion of a valuation report in the notice where the offered price and reports are available for inspection, rejected a claim of demonstrable valuer bias, and accepted that DLOM and the valuation were not manifestly unreasonable, so the reduction stands.
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