Deemed taxation liability where company to LLP migration conditions fail, charging successor or shareholder with resultant profits. Insertion of sub section (4) to section 47A deems amounts of profits or gains not charged under section 45 by virtue of the proviso to clause (xiiib) of section 47 to be chargeable to tax of the successor LLP or the shareholder of the predecessor company for the previous year in which the proviso's conditions are not complied with.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Deemed taxation liability where company to LLP migration conditions fail, charging successor or shareholder with resultant profits.
Insertion of sub section (4) to section 47A deems amounts of profits or gains not charged under section 45 by virtue of the proviso to clause (xiiib) of section 47 to be chargeable to tax of the successor LLP or the shareholder of the predecessor company for the previous year in which the proviso's conditions are not complied with.
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