Attribution of income-tax under section 67(10) to remaining capital assets follows a proportionate allocation formula for specified entities. Attribution of the amount chargeable to income-tax under section 67(10) to capital assets remaining with a specified entity is governed for the purposes of section 72(5) by a defined allocation mechanism. Where the tax charge arises from revaluation of a capital asset or valuation of a self-generated asset or self-generated goodwill of the specified entity, the amount attributable to the capital asset remaining with the entity is determined by a proportionate formula based on the increase in, or recognition of, value of that remaining asset as compared with the aggregate increase in, or recognition of, value of all assets revalued or valued.
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Provisions expressly mentioned in the judgment/order text.
Attribution of income-tax under section 67(10) to remaining capital assets follows a proportionate allocation formula for specified entities.
Attribution of the amount chargeable to income-tax under section 67(10) to capital assets remaining with a specified entity is governed for the purposes of section 72(5) by a defined allocation mechanism. Where the tax charge arises from revaluation of a capital asset or valuation of a self-generated asset or self-generated goodwill of the specified entity, the amount attributable to the capital asset remaining with the entity is determined by a proportionate formula based on the increase in, or recognition of, value of that remaining asset as compared with the aggregate increase in, or recognition of, value of all assets revalued or valued.
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