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...
Dividend remittance to foreign shareholders was permitted despite pending tax demands because those demands were already under challenge and stayed, and the Court found that an indefinite embargo on repatriation was unjustified. Revenue protection was maintained by requiring the company to furnish an auto-renewable interest-bearing FDR of equivalent value, comply with remittance rules, and deduct tax at source; the earlier lien on existing FDRs was lifted. Separately, refund for AY 2021-22 was allowed to be adjusted against the demand for AY 2018-19 on the petitioner's concession, and the Department was protected from any contempt allegation if the refund was adjusted against outstanding demand for AY 2020-21.
Dividend remittance to foreign shareholders was permitted despite pending tax demands because those demands were already under challenge and stayed, and the Court found that an indefinite embargo on repatriation was unjustified. Revenue protection was maintained by requiring the company to furnish an auto-renewable interest-bearing FDR of equivalent value, comply with remittance rules, and deduct tax at source; the earlier lien on existing FDRs was lifted. Separately, refund for AY 2021-22 was allowed to be adjusted against the demand for AY 2018-19 on the petitioner's concession, and the Department was protected from any contempt allegation if the refund was adjusted against outstanding demand for AY 2020-21.
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