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    <title>2012 (6) TMI 938 - BOMBAY HIGH COURT</title>
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    <description>Capital-gains taxability of a rig sale is examined on the basis that the bill of sale transferred all rights and acknowledged consideration on 19 September 1997, while later lease termination and removal from Indian waters did not alter the completed sale. The notes state that the non-resident taxpayer had a permanent establishment in India and the asset remained in India. They further address reassessment beyond four years, stating that independently discovered non-disclosure of the sale and resulting income could satisfy the recorded-reasons requirement without verbatim statutory wording. They also note that a further Tribunal hearing meant that the subsequent pronouncement delay did not raise a substantial legal issue.</description>
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    <pubDate>Wed, 20 Jun 2012 00:00:00 +0530</pubDate>
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      <title>2012 (6) TMI 938 - BOMBAY HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=470388</link>
      <description>Capital-gains taxability of a rig sale is examined on the basis that the bill of sale transferred all rights and acknowledged consideration on 19 September 1997, while later lease termination and removal from Indian waters did not alter the completed sale. The notes state that the non-resident taxpayer had a permanent establishment in India and the asset remained in India. They further address reassessment beyond four years, stating that independently discovered non-disclosure of the sale and resulting income could satisfy the recorded-reasons requirement without verbatim statutory wording. They also note that a further Tribunal hearing meant that the subsequent pronouncement delay did not raise a substantial legal issue.</description>
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      <pubDate>Wed, 20 Jun 2012 00:00:00 +0530</pubDate>
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