Related-party creditor exclusion bars CoC participation where lender rights show policy-making involvement, and post-CIRP assignment cannot cure ineli...
Rectification of apparent typographical errors may proceed without hearing when tax liability, input tax credit, and ruling substance remain unchanged...
Reassessment initiation requires a show-cause notice issued within the applicable limitation period and accompanied by transaction-specific information suggesting income escapement. The information must identify the transaction, the basis of proposed escapement and sufficient particulars to enable an effective response; merely stating an alleged escaped amount is insufficient. Later disclosure cannot cure an initiation lacking those foundational particulars within time. For proportionate rights-share allotments, fresh shares are distinct from pre-existing shares transferred by another person. Where an existing shareholder's percentage holding remains unchanged and no disproportionate benefit arises, the difference between subscription price and fair market value alone does not establish receipt of property for inadequate consideration under Section 56(2)(x).
Reassessment initiation requires a show-cause notice issued within the applicable limitation period and accompanied by transaction-specific information suggesting income escapement. The information must identify the transaction, the basis of proposed escapement and sufficient particulars to enable an effective response; merely stating an alleged escaped amount is insufficient. Later disclosure cannot cure an initiation lacking those foundational particulars within time. For proportionate rights-share allotments, fresh shares are distinct from pre-existing shares transferred by another person. Where an existing shareholder's percentage holding remains unchanged and no disproportionate benefit arises, the difference between subscription price and fair market value alone does not establish receipt of property for inadequate consideration under Section 56(2)(x).
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4935 
