Social forestry expenditure requires activity-based classification, limiting book-profit adjustments and preserving penalty relief where normal additi...
Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Customs Broker due diligence requires prescribed KYC, not detecting misdeclarations discoverable only through physical examination, defeating licence ...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
