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2018 (6) TMI 1455 - AT - Income TaxSection 94(8) application - allotment of additional units without any payment on the basis of holding of such units on any particular date - Held that:- As gone through the provisions of Section 94(8) of the Act and found that all the clauses under (a) to (c) have to be satisfied cumulatively for invoking the said provision. Clause (b) thereof speaks of allotment of additional units without any payment on the basis of holding of such units. In this matter such details as are furnished establish that there is always investment and redemption at very short durations and in such a situation it cannot be said that there is allotment of units without any payment merely on the basis of holding of the earlier units. We, therefore, hold that to the facts of the case on hand, Section 94(8) has no application and any addition made on that basis cannot be sustained.
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