Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
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
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4817 
Join Channel 
