Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
For unquoted equity shares, Rule 11UA(2) gives the assessee the choice of either the NAV method or the DCF method for fair market value, and the Assessing Officer cannot substitute NAV for the method chosen by the assessee. The AO may, however, scrutinise whether the DCF valuation is supported by reliable projections and material; where serious defects remain unexplained, the valuation as filed cannot be accepted. In that situation, the proper course is a fresh valuation by an approved valuer on the DCF basis, with the matter decided afresh in accordance with law. The same approach applies where later-year facts are identical.
For unquoted equity shares, Rule 11UA(2) gives the assessee the choice of either the NAV method or the DCF method for fair market value, and the Assessing Officer cannot substitute NAV for the method chosen by the assessee. The AO may, however, scrutinise whether the DCF valuation is supported by reliable projections and material; where serious defects remain unexplained, the valuation as filed cannot be accepted. In that situation, the proper course is a fresh valuation by an approved valuer on the DCF basis, with the matter decided afresh in accordance with law. The same approach applies where later-year facts are identical.
Note: It is a system-generated summary and is for quick reference only.
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