Concessional corporate tax option under section 115BAA survives procedural documentary lapses when statutory compliance and earlier exercise are estab...
Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Buy-back of shares by an Indian subsidiary was treated as a corporate reorganisation because the transaction involved transfer of shares within the same corporate group and changed the form of the foreign shareholder's interest without altering its underlying ownership. Relying on the understanding of corporate restructuring reflected in professional guidance and the object of Article 13(5) of the India-Netherlands DTAA, the Tribunal held that the resulting gains fell within that treaty provision. The gains were therefore not taxable in India, and the assessee's appeal was allowed by majority.
Buy-back of shares by an Indian subsidiary was treated as a corporate reorganisation because the transaction involved transfer of shares within the same corporate group and changed the form of the foreign shareholder's interest without altering its underlying ownership. Relying on the understanding of corporate restructuring reflected in professional guidance and the object of Article 13(5) of the India-Netherlands DTAA, the Tribunal held that the resulting gains fell within that treaty provision. The gains were therefore not taxable in India, and the assessee's appeal was allowed by majority.
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