Advance-ruling mechanism governs pending GST classification, exemption and taxability disputes, limiting writ review once the specialised forum functi...
Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
Section 56(2)(vii)(c) is discussed as applying where shares or securities are received from another person for inadequate consideration. The notes distinguish a fresh allotment from a transfer of existing property: newly issued shares arise from unissued share capital and do not pre-exist as property transferred by another person. On a strict construction of the deeming provision, the term "receives" is treated as requiring prior existence of the property. The discussion records that the provision was considered inapplicable to fresh share allotments, resulting in deletion of the related additions; the Revenue's challenge based on a sibling's earlier case was treated as academic.
Section 56(2)(vii)(c) is discussed as applying where shares or securities are received from another person for inadequate consideration. The notes distinguish a fresh allotment from a transfer of existing property: newly issued shares arise from unissued share capital and do not pre-exist as property transferred by another person. On a strict construction of the deeming provision, the term "receives" is treated as requiring prior existence of the property. The discussion records that the provision was considered inapplicable to fresh share allotments, resulting in deletion of the related additions; the Revenue's challenge based on a sibling's earlier case was treated as academic.
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