Rule 11 introduces detailed valuation rules for listed, unlisted, and controlling shareholdings, partnership interests, and foreign company assets to determine fair market value under section 9(2).
The Court refused pre-arrest bail after noting admissions and central involvement in alleged GST evasion of over ₹20 crore. It held that economic offences require strict scrutiny and custodial interrogation may be necessary.
Holding that the GST Act prescribes separate assessment and limitation for each year, the Court quashed a notice combining multiple tax periods. Authorities were granted liberty to issue fresh notices in compliance with the Act.
The Court ordered adjudication of GST show cause notice on royalty but directed that no recovery be made and implementation be kept in abeyance pending the Supreme Court’s decision.
The Tribunal ruled that exercising an option to convert warrants into shares does not amount to transfer under Section 2(47). Since no consideration was received and shares were not sold, no capital gain arose.
Rule 10 sets out detailed definitions of accountant, management control, observable price, book value, and balance sheet standards to ensure clarity and uniform application under Rules 11 and 12 of the Draft Income-tax Rules, 2026.
The Tribunal found that denial of foreign tax credit during return processing was improper where Form 67 and the return were filed together. The Assessing Officer was directed to verify and allow credit.
The Tribunal held that the reassessment notice was time-barred under the Supreme Court ruling on surviving period. Notices issued beyond the permissible limit were declared invalid.
Tribunal upheld deletion of unsecured loan addition after finding identity, creditworthiness, and genuineness established through PAN, ITRs, bank statements, and TDS records.
The Tribunal held that deposits received from members of a registered cooperative society cannot be treated as unexplained credits when supported by books and member-wise records.