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...
Compensation paid under cancellation arrangements for share-sale agreements was treated as deductible expenditure in computing long-term capital gains because the transaction was found genuine and not a colourable device. The payment had a direct nexus with the eventual transfer of shares at a higher price and was accepted as expenditure incurred wholly and exclusively in connection with the transfer. The objection based on Rule 46A also failed because the material was already in the public domain and, in any event, the Commissioner (Appeals) may make further inquiry where the Assessing Officer has not done so. The disallowance was deleted.
Compensation paid under cancellation arrangements for share-sale agreements was treated as deductible expenditure in computing long-term capital gains because the transaction was found genuine and not a colourable device. The payment had a direct nexus with the eventual transfer of shares at a higher price and was accepted as expenditure incurred wholly and exclusively in connection with the transfer. The objection based on Rule 46A also failed because the material was already in the public domain and, in any event, the Commissioner (Appeals) may make further inquiry where the Assessing Officer has not done so. The disallowance was deleted.
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