https://www.taxtmi.com/caselaws?id=784995 Whether assets received on demerger attracted income under s.56(2)(x)-Tribunal (ITAT) held that the scheme satisfied s.2(19AA) read with s.47(vi); Rule 11UA (valuation) cannot be imported into s.2(19AA)(iv) and registered valuer's swap ratio was acceptable, so the exception to s.56(2)(x) applied and the addition was deleted. Outcome: deletion of addition under s.56(2)(x) upheld. Whether NCLT sanction binds tax authorities-ITAT affirmed NCLT approval does not preclude independent tax scrutiny by AO; tax consequences may be examined separately. Outcome: Revenue remains free to examine tax implications. Whether s.194IC TDS applied to payment under unregistered MOU-Tribunal agreed s.194IC did not apply as the agreement did not qualify as a "specified agreement." Outcome: direction to refer TDS default set aside; appeal allowed on this point. en-us Mon, 12 Jan 2026 00:00:00 +0530 Thu, 15 Jan 2026 08:41:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784995 Whether assets received on demerger attracted income under s.56(2)(x)-Tribunal (ITAT) held that the scheme satisfied s.2(19AA) read with s.47(vi); Rule 11UA (valuation) cannot be imported into s.2(19AA)(iv) and registered valuer's swap ratio was acceptable, so the exception to s.56(2)(x) applied and the addition was deleted. Outcome: deletion of addition under s.56(2)(x) upheld. Whether NCLT sanction binds tax authorities-ITAT affirmed NCLT approval does not preclude independent tax scrutiny by AO; tax consequences may be examined separately. Outcome: Revenue remains free to examine tax implications. Whether s.194IC TDS applied to payment under unregistered MOU-Tribunal agreed s.194IC did not apply as the agreement did not qualify as a "specified agreement." Outcome: direction to refer TDS default set aside; appeal allowed on this point. Case-Laws Income Tax Mon, 12 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784995