Reassessment notices require timely, transaction-specific escapement information; proportionate rights-share allotments may fall outside inadequate-consideration taxation.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Reassessment initiation requires a show-cause notice issued within the applicable limitation period and accompanied by transaction-specific information suggesting income escapement. The information must identify the transaction, the basis of proposed escapement and sufficient particulars to enable an effective response; merely stating an alleged escaped amount is insufficient. Later disclosure cannot cure an initiation lacking those foundational particulars within time. For proportionate rights-share allotments, fresh shares are distinct from pre-existing shares transferred by another person. Where an existing shareholder's percentage holding remains unchanged and no disproportionate benefit arises, the difference between subscription price and fair market value alone does not establish receipt of property for inadequate consideration under Section 56(2)(x).....