Admissibility of inquiry statements and electronic printouts in customs adjudication requires witness examination and cross-examination before relianc...
Page of 4816
Press 'Enter' after typing page number.
6921 to 6940 of 96301 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Section 47(vii) exemption was held confined to transfers of capital assets on amalgamation and inapplicable where the assessee's shares in the amalgamating company were held as stock-in-trade; in such cases, taxability is governed by Section 28 as business income. For Section 28, mere sanction/appointed date does not trigger charge; the taxable event arises only on actual allotment of new shares, and only if the substituted shares confer a real, presently realisable commercial benefit with ascertainable value. Whether the shares were stock-in-trade or investment, and whether the allotted shares were freely realisable/subject to restrictions, was treated as fact-dependent with burden on Revenue; matter was remitted to the Tribunal, while the legal principle was decided in Revenue's favour and the HC judgment affirmed. - SC
Section 47(vii) exemption was held confined to transfers of capital assets on amalgamation and inapplicable where the assessee's shares in the amalgamating company were held as stock-in-trade; in such cases, taxability is governed by Section 28 as business income. For Section 28, mere sanction/appointed date does not trigger charge; the taxable event arises only on actual allotment of new shares, and only if the substituted shares confer a real, presently realisable commercial benefit with ascertainable value. Whether the shares were stock-in-trade or investment, and whether the allotted shares were freely realisable/subject to restrictions, was treated as fact-dependent with burden on Revenue; matter was remitted to the Tribunal, while the legal principle was decided in Revenue's favour and the HC judgment affirmed. - SC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4816 
Join Channel 
