Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Section 56(2)(viib) share-premium additions may not arise where the issue price of unquoted shares exceeds the Rule 11UA value by no more than 10%. The CBDT's curative safe-harbour amendment treats the issue price within that permissible variation as fair market value. Applying this safe harbour, an addition for excess share premium within the 10% range was treated as unsustainable and deleted.
Section 56(2)(viib) share-premium additions may not arise where the issue price of unquoted shares exceeds the Rule 11UA value by no more than 10%. The CBDT's curative safe-harbour amendment treats the issue price within that permissible variation as fair market value. Applying this safe harbour, an addition for excess share premium within the 10% range was treated as unsustainable and deleted.
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