Income Tax

Background of the case In a recent ruling, the Chennai Tribunal (hereinafter referred to as “the Tribunal” or “ITAT”) in the case of Valeo Bayen (“the Assessee”) examined the scope and application of Section 47(iv) of the Income-tax Act, 1961 (“the Act”) in the context of an intra-group share transfer by the Assessee to its […]

Background of the case In a recent ruling, the Mumbai Income-tax Appellate Tribunal (hereinafter referred to as “the Tribunal” or “ITAT”), in the case of Sterling Holiday Resorts Limited (formerly known as Thomas Cook Insurance Services India Limited) (“the Assessee” or “SHRL” or “TCISL”), examined the statutory conditions governing a tax-neutral demerger under Section 2(19AA) […]

Background of the case In the recent ruling of the Kolkata Tribunal (“the Tribunal” or “ITAT”) in the case of Emami Realty Limited (“the assessee”), the Tribunal examined the scope and interplay of Sections 2(19AA), 47(vib), and 56(2)(x) of the Income-tax Act, 1961 (“the Act”) in the context of a court-approved demerger. The central controversy […]