https://www.taxtmi.com/circulars?id=64882 A deeming rule treats transfers on dissolution or reconstitution as if the specified entity transferred capital assets or stock in trade at fair market value, taxing resulting profits in the hands of the specified entity in the year the asset is received. The substituted receipt provision charges profits on amounts or assets received on reconstitution as capital gains of the specified entity and prescribes an attribution mechanism, with rule 8AB clarified to apply to assets forming part of a block so that attributed amounts reduce future consideration and adjust written down value or capital gains computation as applicable. en-us Fri, 02 Jul 2021 00:00:00 +0530 Sat, 03 Jul 2021 12:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/circulars?id=64882 A deeming rule treats transfers on dissolution or reconstitution as if the specified entity transferred capital assets or stock in trade at fair market value, taxing resulting profits in the hands of the specified entity in the year the asset is received. The substituted receipt provision charges profits on amounts or assets received on reconstitution as capital gains of the specified entity and prescribes an attribution mechanism, with rule 8AB clarified to apply to assets forming part of a block so that attributed amounts reduce future consideration and adjust written down value or capital gains computation as applicable. Circulars Income Tax Fri, 02 Jul 2021 00:00:00 +0530 https://www.taxtmi.com/circulars?id=64882