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’.
No deduction towards interest u/s S. 36(1)(iii) for new unit even in the case of an assessee already in the same business
Reopening u/s 147 for 100% dis-allowance of Bogus Sales/ Purchases as against 2.50% dis-allowance done during regular assessment
Threshold limit u/s 194IA for TDS not to be checked with the Amount mentioned in sale deed vis a vis individual share of each co-owner