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Jurisdictional facts in certificate-of-origin discrepancies can support customs show-cause proceedings, leaving factual explanations for departmental ...
Addition u/s 56(1) - shares received by the assessee company at the time of amalgamation - the Revenue is not precluded from ascertaining as to whether the scheme of amalgamation was in compliance with the provisions of the Act so as to avail the benefit of Section 47(vi) of the Act. - the scheme of amalgamation of EBPL with the assessee company cannot be disregarded nor can it be held to be a ‘colourable device’. - AT
Addition u/s 56(1) - shares received by the assessee company at the time of amalgamation - the Revenue is not precluded from ascertaining as to whether the scheme of amalgamation was in compliance with the provisions of the Act so as to avail the benefit of Section 47(vi) of the Act. - the scheme of amalgamation of EBPL with the assessee company cannot be disregarded nor can it be held to be a ‘colourable device’. - AT
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