Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
Food import sampling requirements support provisional release where unseized consignments conform to standards and raw areca classification is unestab...
Diagnostic microcuvette classification follows sole-use analytical function, placing specialised disposable cuvettes with their analyser rather than g...
Customs Broker licensing proceedings fail when their offence-report foundation collapses and authorisation, advisory, and KYC duties remain unbreached...
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Addition u/s.56(2)(viib) - Determination of FMV of shares - Admittedly, provision of section 56(2)(viib) of the Act do not prescribe only one method for valuation of fair market value of share which is evident from the perusal of the section itself, as reproduced above. The assessee can also justify the fair market value of the shares based on the valuation of its asset as on the date of issue of shares including both tangible and intangible assets. Therefore the finding of the Revenue authorities in the present case that valuation of FMV as per the Rule 11UA is not justified, we hold is not in accordance with law - valuation report of FMV of the shares cannot be based on one method only. - AT
Addition u/s.56(2)(viib) - Determination of FMV of shares - Admittedly, provision of section 56(2)(viib) of the Act do not prescribe only one method for valuation of fair market value of share which is evident from the perusal of the section itself, as reproduced above. The assessee can also justify the fair market value of the shares based on the valuation of its asset as on the date of issue of shares including both tangible and intangible assets. Therefore the finding of the Revenue authorities in the present case that valuation of FMV as per the Rule 11UA is not justified, we hold is not in accordance with law - valuation report of FMV of the shares cannot be based on one method only. - AT
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