Definition of property expanded to include company-related rights, and transfer clarified, altering tax application. Amendments clarify that property includes any rights in or in relation to an Indian company and that transfer includes disposing of or creating any interest in an asset in any manner whatsoever, both with retrospective effect; the Commissioner definition is expanded to include the Director of Income-tax retrospectively; and the demerger rule is amended to exclude the share-issue requirement where the resulting company is itself a shareholder of the demerged company, with effect for specified assessment years.
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Provisions expressly mentioned in the judgment/order text.
Definition of property expanded to include company-related rights, and transfer clarified, altering tax application.
Amendments clarify that property includes any rights in or in relation to an Indian company and that transfer includes disposing of or creating any interest in an asset in any manner whatsoever, both with retrospective effect; the Commissioner definition is expanded to include the Director of Income-tax retrospectively; and the demerger rule is amended to exclude the share-issue requirement where the resulting company is itself a shareholder of the demerged company, with effect for specified assessment years.
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