Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Validity of Scheme of arrangement between the Petitioner and its Shareholders - Proceedings under Income Tax were pending - It will not be proper to permit the Petitioner Company to gift its shares in TAAL to its Shareholders as envisaged under the Scheme. The Court will not put its imprimatur on such a Scheme. - it is clear that the Scheme is illegal and contrary to law and hence cannot be sanctioned by this Court. - HC
Validity of Scheme of arrangement between the Petitioner and its Shareholders - Proceedings under Income Tax were pending - It will not be proper to permit the Petitioner Company to gift its shares in TAAL to its Shareholders as envisaged under the Scheme. The Court will not put its imprimatur on such a Scheme. - it is clear that the Scheme is illegal and contrary to law and hence cannot be sanctioned by this Court. - HC
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