Home Case Index All Cases Income Tax Income Tax + HC Income Tax - 2014 (4) TMI HC This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2014 (4) TMI 893 - HC - Income TaxDeletion made u/s 28(iv) of the Act – Benefit to the assessee by the allotment of shares – Held that:- The Tribunal has found that the allotment is made much prior to the performance of M/s. Reliance - when the assessee was not having any direct business relations or not having carried out any business with M/s. Reliance Communications either in the past or during the year, then the assessee cannot be said to be having any business or professional relationship with M/s.Reliance Communication Ltd. - Reliance Communication and Reliance Group of Companies are independent entities and even for taxation purposes, they are separate and independent - the finding of fact that section 28(iv) has no application, is based on all the materials produced and which have been noted by the Tribunal - once the Tribunal has come to a conclusion that section 28(iv) has no application, then, any further aspect of the matter need not be probed or investigated – thus, no substantial question of law arises for consideration – Decided against Revenue.
|