Transfer-pricing comparability filters require fresh arm's-length analysis, while delayed receivables need separate reconsideration with working-capit...
Section 153C jurisdiction requires timely deemed search and assessee-specific satisfaction material; otherwise reassessment must use the proper statut...
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 4886 
