Separate speaking orders on reopening objections are mandatory; deciding them within reassessment invalidates jurisdiction and precludes revival of st...
Compulsorily convertible debentures remain debt before conversion, preventing transfer-pricing and interest-deduction disallowances on the stated fact...
Stock-in-trade transfer taxability follows possession and consideration, not later conveyance registration, limiting deemed-value provisions to the ac...
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Addition u/s 56(2)(vii) - real owners - partners v/s firm - property purchased by assessee-partner less than guideline value of the property - applying purposive construction to the facts of the present case, the property is deemed to have been acquired by the firm only and not by individual partners. Provisions of Sec.56(2)(vii)(b)(ii) could not be pressed into service since these provisions do not apply to partnership firm at the relevant point of time. - AT
Addition u/s 56(2)(vii) - real owners - partners v/s firm - property purchased by assessee-partner less than guideline value of the property - applying purposive construction to the facts of the present case, the property is deemed to have been acquired by the firm only and not by individual partners. Provisions of Sec.56(2)(vii)(b)(ii) could not be pressed into service since these provisions do not apply to partnership firm at the relevant point of time. - AT
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