Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Addition u/s 56(2)(viia) - taking fair market value of buy back of shares by assessee from its holding company a company incorporated in USA - the provisions of section 2(22)(d) r.w.s.115O of the Act would not apply in the hands of the assessee, since the shareholders have received the money in lieu of buyback of shares by assessee of the parent company - we do not agree that on the issue of buyback of shares, assessee has acquired any share of any other company which would become property of the recipient company. - AT
Addition u/s 56(2)(viia) - taking fair market value of buy back of shares by assessee from its holding company a company incorporated in USA - the provisions of section 2(22)(d) r.w.s.115O of the Act would not apply in the hands of the assessee, since the shareholders have received the money in lieu of buyback of shares by assessee of the parent company - we do not agree that on the issue of buyback of shares, assessee has acquired any share of any other company which would become property of the recipient company. - AT
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