Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Addition u/s 56(2)(vii)(c) - related person - allotment of equity shares @ Rs. 10/- - book value of shares prior to allotment worked out at Rs. 552/- per share - the shares were issued by the company to the existing shareholders who are husband and wife being close relatives - The assessee’s case squarely falls under the provision of section 56(2)(vii)(c) and the same does not fall under any exceptions as provided in this explanation to proviso to section 56(1)(vii)(c) - the AO has rightly assessed the differential value of shares received by assessee - AT
Addition u/s 56(2)(vii)(c) - related person - allotment of equity shares @ Rs. 10/- - book value of shares prior to allotment worked out at Rs. 552/- per share - the shares were issued by the company to the existing shareholders who are husband and wife being close relatives - The assessee’s case squarely falls under the provision of section 56(2)(vii)(c) and the same does not fall under any exceptions as provided in this explanation to proviso to section 56(1)(vii)(c) - the AO has rightly assessed the differential value of shares received by assessee - AT
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