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...
Where reassessment was triggered by documents found in a search on a third party, the Revenue had to proceed under the special search-assessment mechanism for "other person" cases and could not invoke general reassessment under section 147 on the same material. The Tribunal held that assumption of jurisdiction under section 147 was invalid because the very basis of action arose from third-party search material, and the reassessment was therefore vitiated. The remaining grounds were treated as academic, and the reassessment proceedings were quashed.
Where reassessment was triggered by documents found in a search on a third party, the Revenue had to proceed under the special search-assessment mechanism for "other person" cases and could not invoke general reassessment under section 147 on the same material. The Tribunal held that assumption of jurisdiction under section 147 was invalid because the very basis of action arose from third-party search material, and the reassessment was therefore vitiated. The remaining grounds were treated as academic, and the reassessment proceedings were quashed.
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