Power to amalgamate: court may sanction amalgamation despite MOA silence, effecting necessary alterations under the statutory scheme.
Sections 391-394 operate as a complete code permitting court-sanctioned schemes to effect amalgamation and to direct necessary alterations in the memorandum and articles; absence of an express amalgamation power in the MOA does not prevent the court from sanctioning and implementing the scheme, except where specific separate procedures (notably reduction of capital) are required. (AI Summary)

Transfer Pricing Officer powers expanded: TPO may determine arms length price for unreported international transactions, binding on assessment.
The Transfer Pricing Officer (TPO) may determine the Arm's Length Price for international transactions noticed during proceedings where the taxpayer failed to report them; the TPO must provide notice and opportunity to be heard, issue a written ALP determination to the Assessing Officer and taxpayer, and the Assessing Officer must compute total income having regard to the TPO's ALP. Legislative amendments expand TPO jurisdiction to unreported transactions and strengthen investigatory powers for on the spot verification. (AI Summary)