Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
ITAT ruled in favor of assessee regarding addition under s. 56(2)(viib) for alleged excess share premium. The disputed amount arose from a nominal rounding difference of Rs. 0.09 per share on allotment of 1 crore equity shares to existing shareholders in proportion to their shareholding ratio. The Tribunal found the CIT(A)'s order unsustainable as the share allotment maintained original shareholding patterns without substantive premium excess. The technical rounding difference did not constitute premium warranting addition under s. 56(2)(viib). Addition deleted based on assessee's submission demonstrating proportional allotment to existing shareholders with unchanged shareholding ratios.
ITAT ruled in favor of assessee regarding addition under s. 56(2)(viib) for alleged excess share premium. The disputed amount arose from a nominal rounding difference of Rs. 0.09 per share on allotment of 1 crore equity shares to existing shareholders in proportion to their shareholding ratio. The Tribunal found the CIT(A)'s order unsustainable as the share allotment maintained original shareholding patterns without substantive premium excess. The technical rounding difference did not constitute premium warranting addition under s. 56(2)(viib). Addition deleted based on assessee's submission demonstrating proportional allotment to existing shareholders with unchanged shareholding ratios.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
