Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
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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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