Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
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Rule 11UA(2) permits an assessee issuing unquoted equity shares to choose either the Discounted Cash Flow or Net Asset Value method for determining fair market value under section 56(2)(viib). After a prescribed method is chosen, the Assessing Officer may scrutinise the valuation report but cannot replace it with a formula-based valuation merely because projections, management inputs, or standard disclaimers are questioned. Discounted Cash Flow projections cannot be rejected solely by comparison with subsequent performance. Rejection requires demonstrably incorrect data, a wholly erroneous basis, or a wrong valuation approach; absent such defects, the chosen method governs share-premium valuation.
Rule 11UA(2) permits an assessee issuing unquoted equity shares to choose either the Discounted Cash Flow or Net Asset Value method for determining fair market value under section 56(2)(viib). After a prescribed method is chosen, the Assessing Officer may scrutinise the valuation report but cannot replace it with a formula-based valuation merely because projections, management inputs, or standard disclaimers are questioned. Discounted Cash Flow projections cannot be rejected solely by comparison with subsequent performance. Rejection requires demonstrably incorrect data, a wholly erroneous basis, or a wrong valuation approach; absent such defects, the chosen method governs share-premium valuation.
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