Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Addition u/s 56(2)(vii)(c) - related person - allotment of equity shares @ Rs. 10/- - book value of shares prior to allotment worked out at Rs. 552/- per share - the shares were issued by the company to the existing shareholders who are husband and wife being close relatives - The assessee’s case squarely falls under the provision of section 56(2)(vii)(c) and the same does not fall under any exceptions as provided in this explanation to proviso to section 56(1)(vii)(c) - the AO has rightly assessed the differential value of shares received by assessee - AT
Addition u/s 56(2)(vii)(c) - related person - allotment of equity shares @ Rs. 10/- - book value of shares prior to allotment worked out at Rs. 552/- per share - the shares were issued by the company to the existing shareholders who are husband and wife being close relatives - The assessee’s case squarely falls under the provision of section 56(2)(vii)(c) and the same does not fall under any exceptions as provided in this explanation to proviso to section 56(1)(vii)(c) - the AO has rightly assessed the differential value of shares received by assessee - AT
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