https://www.taxtmi.com/caselaws?id=314523 The Madras HC dismissed writ petitions challenging reassessment orders under Section 148A(d) regarding taxability of share buyout proceeds and interest received thereon. The court held that the assessing authority correctly concluded no capital gains arose from the share buyout transaction per Apex Court order, as it was neither an inter vivos transfer nor deemed dividend under Section 2(22)(e). However, the court found no issue with the authority's prima facie conclusion that income escaped assessment. The interest liability was deemed a timing difference properly taxable in AY 2019-20 based on accrual principles when the Apex Court order was passed. The court rejected petitioner's argument that taxability wasn't adequately specified in the showcause notice, noting Section 148A(b) notices need only broadly outline reassessment basis. en-us Thu, 27 Apr 2023 00:00:00 +0530 Mon, 17 Jun 2024 13:48:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=314523 The Madras HC dismissed writ petitions challenging reassessment orders under Section 148A(d) regarding taxability of share buyout proceeds and interest received thereon. The court held that the assessing authority correctly concluded no capital gains arose from the share buyout transaction per Apex Court order, as it was neither an inter vivos transfer nor deemed dividend under Section 2(22)(e). However, the court found no issue with the authority's prima facie conclusion that income escaped assessment. The interest liability was deemed a timing difference properly taxable in AY 2019-20 based on accrual principles when the Apex Court order was passed. The court rejected petitioner's argument that taxability wasn't adequately specified in the showcause notice, noting Section 148A(b) notices need only broadly outline reassessment basis. Case-Laws Income Tax Thu, 27 Apr 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=314523