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...
Attachment of Pre Offence Mortgaged Property remains possible under PMLA; secured creditors may pursue statutory claim and seek auction with undertaki...
An unregistered joint development arrangement did not constitute a transfer under section 2(47)(v) because it had no legal efficacy for section 53-A, following Balbir Singh Maini. Section 2(47)(vi) also did not apply, as the transaction had not enabled enjoyment of the property as a purported owner and there was no movement of consideration or transfer, symbolically or constructively, before the relevant year-end. Applying B.C. Srinivasa Setty, the Court held that the charging and computation provisions operate as an integrated code, and where no real profit or gain had arisen, sections 45 and 48 could not be invoked. No taxable transfer or accrued capital gain arose for the year.
An unregistered joint development arrangement did not constitute a transfer under section 2(47)(v) because it had no legal efficacy for section 53-A, following Balbir Singh Maini. Section 2(47)(vi) also did not apply, as the transaction had not enabled enjoyment of the property as a purported owner and there was no movement of consideration or transfer, symbolically or constructively, before the relevant year-end. Applying B.C. Srinivasa Setty, the Court held that the charging and computation provisions operate as an integrated code, and where no real profit or gain had arisen, sections 45 and 48 could not be invoked. No taxable transfer or accrued capital gain arose for the year.
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