Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Addition u/s 56(2)(viia) - shares received by the assessee company on account of amalgamation, for a price lower than the Fair Market Value (F.M.V) of the shares - Admittedly, the assessee is a company in which public are not substantially interested. Further, the assessee had received “any property” being shares of a company during the previous year relevant to the assessment year below the fair market value. - CIT(A) wrongly deleted the penalty - Additions confirmed - AT
Addition u/s 56(2)(viia) - shares received by the assessee company on account of amalgamation, for a price lower than the Fair Market Value (F.M.V) of the shares - Admittedly, the assessee is a company in which public are not substantially interested. Further, the assessee had received “any property” being shares of a company during the previous year relevant to the assessment year below the fair market value. - CIT(A) wrongly deleted the penalty - Additions confirmed - AT
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