Insurer's investment gains and investment write-downs face Section 263 revision; enquiry upheld, Rule 5(b)(ii) lapse sustained, late corrigendum quash...
Assessment in the earlier company name was held valid where the assessee's own communications continued to use the old name, creating a bona fide impression on the tax authority; consequently the assessment was not void. Separately, additions treating subscribed share capital and premium as not genuine were sustained because the offered valuation was unacceptable, investor creditworthiness and non-responses were unsatisfactory, and the transactional sequence indicated profiteering through transfer; therefore the premium component was disallowed and additions upheld under the tax provisions addressing non-genuine share allotments and deemed income.
Assessment in the earlier company name was held valid where the assessee's own communications continued to use the old name, creating a bona fide impression on the tax authority; consequently the assessment was not void. Separately, additions treating subscribed share capital and premium as not genuine were sustained because the offered valuation was unacceptable, investor creditworthiness and non-responses were unsatisfactory, and the transactional sequence indicated profiteering through transfer; therefore the premium component was disallowed and additions upheld under the tax provisions addressing non-genuine share allotments and deemed income.
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