Proceeds of crime: provisional attachment confirmed; equivalent value attachment and acquisition date fair market value upheld, Covid exclusion preser...
Effective service requirement: officers must explore alternative service modes beyond the GST portal and afford personal hearing; non-compliance voids...
Addition under section 56(2)(viib) on CCPS premium was deleted where the shares were issued under a reorganisation to the parent and existing shareholders, the valuation was supported by registered valuers or a merchant banker under Rule 11UA, and the transaction was not shown to be unaccounted money. The Tribunal also held that conversion of earlier CCPS into equity during the year did not attract section 56(2)(viib) for that assessment year. A year-end management fee reversal was remanded for fresh verification because the explanation lacked supporting evidence. Payments to MTH for transformation and related hotel services were held revenue in nature, and section 40A(2) was found inapplicable.
Addition under section 56(2)(viib) on CCPS premium was deleted where the shares were issued under a reorganisation to the parent and existing shareholders, the valuation was supported by registered valuers or a merchant banker under Rule 11UA, and the transaction was not shown to be unaccounted money. The Tribunal also held that conversion of earlier CCPS into equity during the year did not attract section 56(2)(viib) for that assessment year. A year-end management fee reversal was remanded for fresh verification because the explanation lacked supporting evidence. Payments to MTH for transformation and related hotel services were held revenue in nature, and section 40A(2) was found inapplicable.
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