https://www.taxtmi.com/caselaws?id=784439 Conversion of government loan liability and accrued interest into equity by allotment of shares was held not to constitute remission/cessation of liability under s.41(1)(a); following prior HC precedent, the resulting equity accretion was not taxable as deemed profits, so the deletion of addition was upheld for the assessee. Contributions to an erstwhile unrecognised provident/pension fund were held allowable because post-amalgamation approval by the CIT had to relate back to the HC-approved effective amalgamation date; the disallowance on "unapproved fund" was set aside for the assessee. Provision for insurance fund/no-fault liability was allowable only on actual payment based on statutory/court-determined liability; the assessee's broader claim was rejected for the revenue. Set-off under s.72A was allowed as the amalgamated entity owned an "industrial undertaking" engaged in manufacture (bus body building), satisfying statutory conditions; the assessee succeeded. Share capital increase expenses were held capital in nature under SC law; the assessee failed. en-us Tue, 16 Dec 2025 00:00:00 +0530 Mon, 05 Jan 2026 08:04:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784439 Conversion of government loan liability and accrued interest into equity by allotment of shares was held not to constitute remission/cessation of liability under s.41(1)(a); following prior HC precedent, the resulting equity accretion was not taxable as deemed profits, so the deletion of addition was upheld for the assessee. Contributions to an erstwhile unrecognised provident/pension fund were held allowable because post-amalgamation approval by the CIT had to relate back to the HC-approved effective amalgamation date; the disallowance on "unapproved fund" was set aside for the assessee. Provision for insurance fund/no-fault liability was allowable only on actual payment based on statutory/court-determined liability; the assessee's broader claim was rejected for the revenue. Set-off under s.72A was allowed as the amalgamated entity owned an "industrial undertaking" engaged in manufacture (bus body building), satisfying statutory conditions; the assessee succeeded. Share capital increase expenses were held capital in nature under SC law; the assessee failed. Case-Laws Income Tax Tue, 16 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784439