Admission of additional evidence under remand rules must await a meaningful remand report; failure to do so breaches natural justice and mandates rema...
Export Obligation Discharge Certificates for EPCG compliance cannot be questioned by Customs unless DGFT adjudicates and cancels them, so demands quas...
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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