Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Addition u/s 56(2)(viib) - allegation of Share premium received by assessee was in excess of Fair Market Value of shares - Method of valuation - AO can scrutinize the valuation report only if some arithmetical mistakes are found, he may make necessary adjustments. It is not open for the AO to challenge or change the method of valuation, once opted by the assessee and to modify the figures as per his own whims and fancies. - AT
Addition u/s 56(2)(viib) - allegation of Share premium received by assessee was in excess of Fair Market Value of shares - Method of valuation - AO can scrutinize the valuation report only if some arithmetical mistakes are found, he may make necessary adjustments. It is not open for the AO to challenge or change the method of valuation, once opted by the assessee and to modify the figures as per his own whims and fancies. - AT
Note: It is a system-generated summary and is for quick reference only.