Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Public servant status under anti-corruption law extends to recognised stock exchange leadership; constitutional and sanction challenges do not succeed...
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Share premium received during the relevant previous year was treated as within the scope of the anti-abuse rule even though the shares had been allotted earlier, because the trigger is receipt of consideration in excess of face value in the year of receipt. At the same time, the addition could not stand where the Assessing Officer rejected the assessee's discounted cash flow valuation without showing any defect, substituted no valid fair market value, and taxed the entire premium without proving any excess over fair market value. The Tribunal accepted the assessee's choice of valuation method and sustained no addition on that basis.
Share premium received during the relevant previous year was treated as within the scope of the anti-abuse rule even though the shares had been allotted earlier, because the trigger is receipt of consideration in excess of face value in the year of receipt. At the same time, the addition could not stand where the Assessing Officer rejected the assessee's discounted cash flow valuation without showing any defect, substituted no valid fair market value, and taxed the entire premium without proving any excess over fair market value. The Tribunal accepted the assessee's choice of valuation method and sustained no addition on that basis.
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