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...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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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