Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
HC dismissed the petition challenging the rejection of a request for relaxation under Rule 9C read with Section 72A regarding carry-forward of losses from amalgamated companies. The court determined that the petitioner failed to achieve the required production capacity (50%) even during the requested three-year extension period. The court emphasized that Section 72A's objective is not merely to encourage corporate restructuring but to extend benefits only where amalgamating companies' industrial undertakings are genuinely revived or continued. The petitioner's multiple requests to modify conditions-first seeking time extensions and later requesting reduced production thresholds (from 50% to 36-42%)-were found unmeritorious, as the application was filed just one day before the expiry of the four-year post-amalgamation period.
HC dismissed the petition challenging the rejection of a request for relaxation under Rule 9C read with Section 72A regarding carry-forward of losses from amalgamated companies. The court determined that the petitioner failed to achieve the required production capacity (50%) even during the requested three-year extension period. The court emphasized that Section 72A's objective is not merely to encourage corporate restructuring but to extend benefits only where amalgamating companies' industrial undertakings are genuinely revived or continued. The petitioner's multiple requests to modify conditions-first seeking time extensions and later requesting reduced production thresholds (from 50% to 36-42%)-were found unmeritorious, as the application was filed just one day before the expiry of the four-year post-amalgamation period.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
