Haresh ShahThe recent ruling by the Mumbai Income-tax Appellate Tribunal (ITAT) in the case of Sterling Holiday Resorts Limited v. DCIT serves as a stark reminder of the "structural tension" between commercial coherence and rigid statutory compliance in Indian tax law. The decision, which resulted in the denial of over ₹240 crore in tax benefits, underscores that even court-approved schemes must strictly adhere to the literal text of the Income-...
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