Embezzlement losses in charitable institutions remain allowable when misappropriation is established, irrecoverable, and not a specified-person benefi...
National long-distance undertaking status supports deduction where separately licensed infrastructure, resources, revenue, and expenditure establish c...
Agency reimbursement income follows contractual deposit-liability computation, while pending deposit collections do not constitute deemed-dividend loa...
Membership-consent thresholds for oppression petitions are satisfied by unchallenged voter-list consents, while unsupported forgery claims require pro...
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Omission of the provision defining related-party purchases as specified domestic transactions, without a saving clause, removed the statutory foundation for penalties for failure to furnish Form 3CEB. Omission is distinguished from repeal: absent a saving provision, it does not preserve a right to initiate or continue proceedings based on the omitted provision. Penalties imposed for the relevant assessment years were therefore unsustainable.
Omission of the provision defining related-party purchases as specified domestic transactions, without a saving clause, removed the statutory foundation for penalties for failure to furnish Form 3CEB. Omission is distinguished from repeal: absent a saving provision, it does not preserve a right to initiate or continue proceedings based on the omitted provision. Penalties imposed for the relevant assessment years were therefore unsustainable.
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