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...
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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