In order to invoke provisions of section 13(2)(c), it is essential to prove that amount paid to person referred to in sub-section (3) of section 13 is in excess of what may be reasonably paid for services rendered
Failure to issue Form No. 16: We would expect the Department of Revenue, particularly, Department of Income Tax to penalise such defaulters and take other strict measures contemplated by law against them: High Court
CBDT clarifies – Section 56(2)(x) even applies to fresh issue of Shares by the Company. Controversy continues
Second proviso to s. 40(a)(ia) is beneficial to the assessee and is declaratory and curative in nature
Exception to the rule – ‘Failure to deal with an argument does not constitute a ‘mistake apparent from the record’ does not apply to a case where a fundamental submission is omitted to be considered by the ITAT’.