1

Commissioner (A) is not empowered to enhance income a new source of income vide 82ITR 9Trib) 176
1

It is assessee’s choice to select a method for determining FMV of shares vide 81 ITR (Trib) (SN) 78
1

No TP adjustment of trade receivables in case of a debt-free company vide 81ITR (Trib) (SN) 94
1

To accord registration as a charitable institution under income tax dominant purpose must be charitable and satisfies the conditions laid down us 2(15) vide 426ITR108 despite having non charitable ancillary objects meant to achieve the dominant purpose
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Transactions with dubious entities is reason enough for case reopening vide 421ITR624

Amalgamation expenses are allowable deduction

ByCA Gopal Nathani

Sep 2, 2020

The Gujarat High Court in CIT v. Akme Electronics & Control (P.) Ltd. (2004) 137TAX263 allowed deduction of legal expenses incurred by the transferor company for the purpose of amalgamation on the ground that the liability to pay such expenses arose in respect of the period when it still continued to exist no matter that the effective date of amalgamation may be prior to the date of sanction of the scheme by the High Court. Like in every case since the amalgamation is resorted to for the smooth and efficient conduct of the business of the transferee company the High Court held that the legal expenses were laid down wholly and exclusively for the purpose of the business of the assessee company.