circumstances of the case the Ld. AO has erred by invoking
section 115QA of the Act and further erred by charging additional tax of distributed ... back of shares of Rs. 71,99,99,211 u/s 115QA of the Act.
6 Under the facts and circumstances of the case
circumstances of the case the Ld. AO has erred by invoking
section 115QA of the Act and further erred by charging additional tax of distributed ... back of shares of Rs. 71,99,99,211 u/s 115QA of the Act.
6 Under the facts and circumstances of the case
facts and circumstances of the case.
2. Non-applicability of Section 115QA of the Act
2.1 The learned CIT(A) erred in interpreting that ... rights of the Appellant to raise grounds on applicability of Section
115QA .
2.2 The learned CIT(A) failed to appreciate the fact that
facts and circumstances of the case.
2. Non-applicability of Section 115QA of the Act
2.1 The learned CIT(A) erred in interpreting that ... rights of the Appellant to raise grounds on applicability of Section
115QA .
2.2 The learned CIT(A) failed to appreciate the fact that
assessee can challenge tax liability under special charging provisions
such as Section 115QA by filing a separate appeal under Section 246A . The Tribunal,
in Texas ... Supreme Court has held that the additional tax payable u/s 115QA can be challenged u/s 246A
10
ITA 2843, 2844 & 2870
assessee can challenge tax liability under special charging provisions
such as Section 115QA by filing a separate appeal under Section 246A . The Tribunal,
in Texas ... Supreme Court has held that the additional tax payable u/s 115QA can be challenged u/s 246A
10
ITA 2843, 2844 & 2870
recognized stock exchange) by
the company referred to in Section 115QA of the Act, shall be exempt from
tax, in the hands of the shareholder ... recognized stock exchange) by the company, as referred to
in section 115QA ]"
The assessing officer noted that as per the above section, the income
recognized stock exchange) by
the company referred to in Section 115QA of the Act, shall be exempt from
tax, in the hands of the shareholder ... recognized stock exchange) by the company, as referred to
in section 115QA ]"
The assessing officer noted that as per the above section, the income
CITYA) erred in deleting the tax levied under Section 115QA of the Income-fax
Act, 1961, on the capital reduction undertaken by the assessee, failing ... therefore liable to tax as per the provisions of the said section 115QA of the
Act?"
2. "Whether on the facts
CITYA) erred in deleting the tax levied under Section 115QA of the Income-fax
Act, 1961, on the capital reduction undertaken by the assessee, failing ... therefore liable to tax as per the provisions of the said section 115QA of the
Act?"
2. "Whether on the facts
