Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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ITAT ruled that Section 56(2)(vii)(c)(ii) does not apply to public limited companies, being exclusively applicable to individuals and HUFs. In a scheme of amalgamation involving share allotment, there is no traditional 'transfer' under Section 47(vii). The High Court-approved amalgamation scheme with its share exchange ratio is conclusive, precluding arguments about discounted share pricing. The tribunal affirmed the CIT(A)'s findings, dismissing the revenue's appeal and holding that the new share issuance does not trigger tax implications under the challenged provision.
ITAT ruled that Section 56(2)(vii)(c)(ii) does not apply to public limited companies, being exclusively applicable to individuals and HUFs. In a scheme of amalgamation involving share allotment, there is no traditional 'transfer' under Section 47(vii). The High Court-approved amalgamation scheme with its share exchange ratio is conclusive, precluding arguments about discounted share pricing. The tribunal affirmed the CIT(A)'s findings, dismissing the revenue's appeal and holding that the new share issuance does not trigger tax implications under the challenged provision.
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