Duplicate PAN allocation requires record verification and deactivation reasons before assessment-related transactions can be attributed to an assessee...
Faceless assessment safeguards require requested personal hearings and adequate final show-cause response time, failing which reassessment is required...
Embezzlement losses in charitable institutions remain allowable when misappropriation is established, irrecoverable, and not a specified-person benefi...
National long-distance undertaking status supports deduction where separately licensed infrastructure, resources, revenue, and expenditure establish c...
Agency reimbursement income follows contractual deposit-liability computation, while pending deposit collections do not constitute deemed-dividend loa...
The case involves the interpretation of u/s 55(2)(b)(i) and u/s 55(2)(aa)(B)(iiia) of the Income Tax Act regarding the cost of acquisition of bonus shares. The Tribunal held that the legislative intent of u/s 55(2)(aa)(B)(iiia) is clear - capital gains on transfer of bonus shares should be computed with a cost of nil if conditions are met. The term "allotted" in sub-clause (iiia) refers to past allotment without specifying a date. The Tribunal rejected the argument that sub-clause (iiia) applies only to shares allotted post-1-4-1995. Referring to Dept. Circular No. 717, the Tribunal emphasized the simplicity of computation intended by the amendment. The Tribunal found that u/s 55(2)(b) applies to financial assets where a price is paid, not to bonus shares acquired without payment. Applying u/s 55(2)(b)(i) to bonus shares would render u/s 55(2)(aa)(B)(iiia) redundant. The Tribunal dismissed the appeal, noting the distinction between capital assets and bonus shares.
The case involves the interpretation of u/s 55(2)(b)(i) and u/s 55(2)(aa)(B)(iiia) of the Income Tax Act regarding the cost of acquisition of bonus shares. The Tribunal held that the legislative intent of u/s 55(2)(aa)(B)(iiia) is clear - capital gains on transfer of bonus shares should be computed with a cost of nil if conditions are met. The term "allotted" in sub-clause (iiia) refers to past allotment without specifying a date. The Tribunal rejected the argument that sub-clause (iiia) applies only to shares allotted post-1-4-1995. Referring to Dept. Circular No. 717, the Tribunal emphasized the simplicity of computation intended by the amendment. The Tribunal found that u/s 55(2)(b) applies to financial assets where a price is paid, not to bonus shares acquired without payment. Applying u/s 55(2)(b)(i) to bonus shares would render u/s 55(2)(aa)(B)(iiia) redundant. The Tribunal dismissed the appeal, noting the distinction between capital assets and bonus shares.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
