https://www.taxtmi.com/caselaws?id=401803 The ITAT dismissed the revenue's appeal, affirming that the rectification order under Section 154 was modified to tax the amount received without consideration. The ITAT held that the forfeited amount of Rs. 12.50 crores was not taxable under Section 51, emphasizing the absence of provisions for such taxation. Additionally, the ITAT ruled that Section 56(2)(ix) was inapplicable for the assessment year in question, clarifying that the forfeited amount would only impact capital gains computation. The judgment highlighted the necessity of applying accurate provisions based on the relevant assessment year, rendering the assessee's appeal against the Section 154 order moot. en-us Mon, 14 Dec 2020 00:00:00 +0530 Wed, 16 Dec 2020 18:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=401803 The ITAT dismissed the revenue's appeal, affirming that the rectification order under Section 154 was modified to tax the amount received without consideration. The ITAT held that the forfeited amount of Rs. 12.50 crores was not taxable under Section 51, emphasizing the absence of provisions for such taxation. Additionally, the ITAT ruled that Section 56(2)(ix) was inapplicable for the assessment year in question, clarifying that the forfeited amount would only impact capital gains computation. The judgment highlighted the necessity of applying accurate provisions based on the relevant assessment year, rendering the assessee's appeal against the Section 154 order moot. Case-Laws Income Tax Mon, 14 Dec 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=401803