Unverified Insight Portal Information Cannot Justify Reassessment Without a Verified Taxpayer-Specific Income-Escape Nexus or Demonstrated Application...
Assessing Officer jurisdiction after statutory transfer invalidates reassessment notices issued by transferor officers and nullifies resulting proceed...
Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
Valid adoption of the DCF method for valuing unquoted equity shares under Rule 11UA requires any assessment correction to remain within that method. Management projections, historical losses, or later financial results may justify scrutiny of assumptions, growth rates, discount factors, terminal value and market conditions, but do not alone permit substitution of the NAV method. Rejection requires identified arithmetical errors, internal inconsistencies, factual inaccuracies, or inputs demonstrably contrary to contemporaneous material or industry norms. Applying these principles, the addition under section 56(2)(viib) was deleted and the Revenue's appeal was dismissed.
Valid adoption of the DCF method for valuing unquoted equity shares under Rule 11UA requires any assessment correction to remain within that method. Management projections, historical losses, or later financial results may justify scrutiny of assumptions, growth rates, discount factors, terminal value and market conditions, but do not alone permit substitution of the NAV method. Rejection requires identified arithmetical errors, internal inconsistencies, factual inaccuracies, or inputs demonstrably contrary to contemporaneous material or industry norms. Applying these principles, the addition under section 56(2)(viib) was deleted and the Revenue's appeal was dismissed.
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TaxTMI 
TaxTMI 
of 4870 
