Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Addition u/s 56(2)(viia) - shares received by the assessee company on account of amalgamation, for a price lower than the Fair Market Value (F.M.V) of the shares - Admittedly, the assessee is a company in which public are not substantially interested. Further, the assessee had received “any property” being shares of a company during the previous year relevant to the assessment year below the fair market value. - CIT(A) wrongly deleted the penalty - Additions confirmed - AT
Addition u/s 56(2)(viia) - shares received by the assessee company on account of amalgamation, for a price lower than the Fair Market Value (F.M.V) of the shares - Admittedly, the assessee is a company in which public are not substantially interested. Further, the assessee had received “any property” being shares of a company during the previous year relevant to the assessment year below the fair market value. - CIT(A) wrongly deleted the penalty - Additions confirmed - AT
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