Background In a recent ruling, the Chennai Income Tax Appellate Tribunal (“ITAT” or “Tribunal”), in the matter of M/s. Aathmika Holdings Pvt. Ltd. v. DCIT (“Assessee” or “Company”), examined the scope of Section 56(2)(x) of the Income-tax Act, 1961 (“IT Act”), specifically regarding the determination of Fair Market Value (FMV) of unlisted shares acquired by […]
Background In a recent ruling, the Delhi High Court (“The Court”), in the case of Equity Intelligence AIF Trust, examined the taxability of Category III AIFs (Alternative Investment Funds) under Section 164 of the Income Tax Act, 1961 (“IT Act”). The key issue pertained to whether the absence of investor names or their beneficial interests […]
Background In a recent ruling, the Mumbai Income-tax Appellate Tribunal (“the Tribunal” or “the ITAT”), in the case of ISC Specialty Chemicals LLP, examined the tax implications of converting a private limited company into a Limited Liability Partnership (LLP) under the provisions of the Income-tax Act, 1961 (“IT Act”). The Tribunal analysed whether the statutory […]
In a recent ruling, the Mumbai Income Tax Appellate Tribunal (ITAT) in the case of iShares ESG Aware MSCI ETF, held that short-term capital loss (STCL) on securities where Securities Transaction Tax (STT) is paid can be set off against short-term capital gains (STCG) from other sources even if those gains are taxed at a […]
Background In a recent ITAT ruling, the Ahmedabad Bench of the ITAT, in the case of Reckitt Benckiser Healthcare India Private Limited (‘Company’ or ‘assessee’), addressed the issue of tax neutrality of a demerger under Section 2(19AA) of the Income-tax Act, 1961 (‘IT Act’). The Tribunal held that the assessee, being non-compliant with Section 2(19AA)(ii), […]
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