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...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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The provisions govern taxation of capital assets or stock-in-trade transfers during entity dissolution or reconstitution. Under both Sec 9B of IT Act 1961 and Cl 8 of IT Bill 2025, such transfers are deemed taxable events with fair market value as consideration. Cl 8 introduces refinements including a two-year limitation for guidelines issuance, 30-day parliamentary review, and modified terminology from "previous year" to "tax year." The framework requires specified entities to recognize deemed transfers in distribution year, compute gains on FMV basis, and subjects proceeds to business income or capital gains tax. Specified persons must document received assets and consider FMV implications. While core principles remain unchanged, Cl 8 enhances administrative procedures and oversight mechanisms for implementation effectiveness.
The provisions govern taxation of capital assets or stock-in-trade transfers during entity dissolution or reconstitution. Under both Sec 9B of IT Act 1961 and Cl 8 of IT Bill 2025, such transfers are deemed taxable events with fair market value as consideration. Cl 8 introduces refinements including a two-year limitation for guidelines issuance, 30-day parliamentary review, and modified terminology from "previous year" to "tax year." The framework requires specified entities to recognize deemed transfers in distribution year, compute gains on FMV basis, and subjects proceeds to business income or capital gains tax. Specified persons must document received assets and consider FMV implications. While core principles remain unchanged, Cl 8 enhances administrative procedures and oversight mechanisms for implementation effectiveness.
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