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...
Deductibility of settlement payments for securities law penalties and treatment of unexplained cash credits in share trading -- Tribunal upholds posit...
Threshold for allottee-initiated insolvency petitions in leasehold real estate upheld; petition admitted after possession letters deemed legally ineff...
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Payments by a trust to related concerns do not automatically attract disallowance under Section 13(1)(c); the statutory test is whether application of income or property results in a direct or indirect benefit to persons specified in Section 13(3), and benefit must be established. Higher profit margins or payments alone are insufficient without comparative or evidential material showing payments were excessive, lacked commercial expediency, or constituted diversion of trust income. Where earlier assessment years with identical facts accepted such payments and there is no change in facts or law, the rule of consistency supports maintaining that view and precludes reopening the transactions under Section 13(1)(c).
Payments by a trust to related concerns do not automatically attract disallowance under Section 13(1)(c); the statutory test is whether application of income or property results in a direct or indirect benefit to persons specified in Section 13(3), and benefit must be established. Higher profit margins or payments alone are insufficient without comparative or evidential material showing payments were excessive, lacked commercial expediency, or constituted diversion of trust income. Where earlier assessment years with identical facts accepted such payments and there is no change in facts or law, the rule of consistency supports maintaining that view and precludes reopening the transactions under Section 13(1)(c).
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