Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
Page of 4803
Press 'Enter' after typing page number.
501 to 520 of 96046 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
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 
of 4803
Join Channel
TaxTMI 
