Co-operative society's mandatory reserve and share capital fixed deposits with banks-interest treated as business income under 80P(2)(a)(iii) deductio...
Income tax reassessment reopening after four years on investigation tip, without s.147 proviso disclosure failure, struck down as borrowed satisfactio...
Dispute concerns whether a settlement resolution applicant (SRA) qualified as a related party and thus was ineligible to submit a resolution plan. The tribunal noted the alleged transaction rested on a non-binding term sheet and no definitive contract or allotment of shares occurred, meaning the factual elements underpinning related party attribution were absent, yet the SRA was treated as a related party. The adjudicating authority previously considered and rejected the ineligibility challenge, rendering that determination final and permitting approval of the resolution plan; accordingly the appellate challenge to that approval was dismissed.
Dispute concerns whether a settlement resolution applicant (SRA) qualified as a related party and thus was ineligible to submit a resolution plan. The tribunal noted the alleged transaction rested on a non-binding term sheet and no definitive contract or allotment of shares occurred, meaning the factual elements underpinning related party attribution were absent, yet the SRA was treated as a related party. The adjudicating authority previously considered and rejected the ineligibility challenge, rendering that determination final and permitting approval of the resolution plan; accordingly the appellate challenge to that approval was dismissed.
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