SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
