Assets in demerger as deemed income under s56(2)(x) over alleged s2(19AA)/Rule11UA breach; addition deleted; unregistered MOU not subject to s194IC

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....Assets received under a scheme of demerger were examined for deemed income treatment under Section 56(2)(x) on the basis that the demerger allegedly breached Section 2(19AA) and valuation norms. The analysis held that Section 2(19AA)(iv) requires proportionate share allotment and that Rule 11UA cannot be read into Section 2(19AA); reliance on a registered valuers computation supported compliance with Section 2(19AA) read with Section 47(vi), with the consequence that the addition under Section 56(2)(x) was deleted. Separately, payments under an unregistered MOU did not constitute a specified agreement attracting TDS, with no TDS liability consequent.....