Case Law Details
Case Name : Periar Trading Company Private Limited Vs ITO (ITAT Mumbai)
Appeal Number : ITA No. 1944/Mum/2018
Date of Judgement/Order : 09/11/2018
Related Assessment Year :
Courts :
All ITAT ITAT Mumbai
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Periar Trading Company Private Limited Vs ITO (ITAT Mumbai)
Conclusion: Conversion of cumulative and compulsory convertible preference shares (CCPS) into equity shares cannot be treated as ‘transfer’ under section 2(4
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OFFHAND
” conversion” – in nthe instant case the point of issue pertains to the subject matter of the ‘transaction’ – being converesion of one type to another type of ‘shares’. Of contextual releance is the point of issue discussed in the Article earlier published on this website- in contrast, thatt was in relation to conversion of one legal entity to another – company to LLP !
The other issue reg. ‘notional interest’ ‘, charged to tax, look through the repeatedly canvassed propostion that income chargeable could only be ‘real income’, not notional; – but is still being carried forward in litigation , in any view, is so reprensible as it is time to cry a halt to the Revenue’s obstinately persistent stance
Over to…!
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