Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
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Transfer of shares to a wholly owned subsidiary was a bona fide commercial reorganisation, not a colourable device, because the Revenue showed no sham, lack of commercial substance, or non-genuineness, and tax benefit alone could not invalidate the transaction. The Tribunal also held that the shares were capital assets and that section 47(iv) exemption applied since the assessee and subsidiary satisfied the statutory ownership conditions. The share valuation challenge failed because the Assessing Officer identified no specific defect in the recognised valuation method, assumptions, or projections. The addition was deleted.
Transfer of shares to a wholly owned subsidiary was a bona fide commercial reorganisation, not a colourable device, because the Revenue showed no sham, lack of commercial substance, or non-genuineness, and tax benefit alone could not invalidate the transaction. The Tribunal also held that the shares were capital assets and that section 47(iv) exemption applied since the assessee and subsidiary satisfied the statutory ownership conditions. The share valuation challenge failed because the Assessing Officer identified no specific defect in the recognised valuation method, assumptions, or projections. The addition was deleted.
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