Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Eligibility for exemption depends on strict construction of the product description; reapers without binder are ineligible, but confiscation and penal...
Primary issue was whether assets received under a scheme of demerger attracted deemed income u/s 56(2)(x) because the demerger allegedly violated Section 2(19AA) and the swap ratio/valuation contravened Rule 11UA. Tribunal held Section 2(19AA)(iv) mandates proportionate share allotment only, Rule 11UA cannot be read into Section 2(19AA), the registered valuer's computation was reasonable and the scheme complied with Section 2(19AA) read with Section 47(vi); consequence: addition u/s 56(2)(x) deleted. Separately, payment under an unregistered MOU was not a "specified agreement" attracting TDS u/s 194IC; consequence: no TDS liability. - ITAT
Primary issue was whether assets received under a scheme of demerger attracted deemed income u/s 56(2)(x) because the demerger allegedly violated Section 2(19AA) and the swap ratio/valuation contravened Rule 11UA. Tribunal held Section 2(19AA)(iv) mandates proportionate share allotment only, Rule 11UA cannot be read into Section 2(19AA), the registered valuer's computation was reasonable and the scheme complied with Section 2(19AA) read with Section 47(vi); consequence: addition u/s 56(2)(x) deleted. Separately, payment under an unregistered MOU was not a "specified agreement" attracting TDS u/s 194IC; consequence: no TDS liability. - ITAT
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