Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
An order granting valuation and the first opportunity to purchase shares was treated as self-operative: once the fair value reports were available, the appellant had to accept the valuation and indicate willingness to buy, without any further formal offer. By rejecting the higher valuation and seeking averaging of the reports, the appellant failed to exercise the first option, so the respondents' right to purchase the shares at the accepted fair value crystallised. The Tribunal also held that a later challenge to the valuation and a belated offer to buy could not revive a waived right after the arrangement had been acted upon. The appeal was dismissed and the sale in favour of the respondents was sustained.
An order granting valuation and the first opportunity to purchase shares was treated as self-operative: once the fair value reports were available, the appellant had to accept the valuation and indicate willingness to buy, without any further formal offer. By rejecting the higher valuation and seeking averaging of the reports, the appellant failed to exercise the first option, so the respondents' right to purchase the shares at the accepted fair value crystallised. The Tribunal also held that a later challenge to the valuation and a belated offer to buy could not revive a waived right after the arrangement had been acted upon. The appeal was dismissed and the sale in favour of the respondents was sustained.
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