Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
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...
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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