Separate speaking orders on reopening objections are mandatory; deciding them within reassessment invalidates jurisdiction and precludes revival of st...
Compulsorily convertible debentures remain debt before conversion, preventing transfer-pricing and interest-deduction disallowances on the stated fact...
Stock-in-trade transfer taxability follows possession and consideration, not later conveyance registration, limiting deemed-value provisions to the ac...
Addition u/s 56 - Issue of shares at premium - The ITAT recognizes that the holding company's value is directly impacted by the performance of its subsidiary and therefore supports the use of Discounted Cash Flow (DCF) Method for valuing the wholly owned subsidiary. - The Tribunal concludes that the method adopted by the assessee, which includes using Net Asset Value Method for its own shares and Discounted Cash Flow Method for valuing the subsidiary, is within the provisions of Rule 11UA of the Income Tax Rules.
Addition u/s 56 - Issue of shares at premium - The ITAT recognizes that the holding company's value is directly impacted by the performance of its subsidiary and therefore supports the use of Discounted Cash Flow (DCF) Method for valuing the wholly owned subsidiary. - The Tribunal concludes that the method adopted by the assessee, which includes using Net Asset Value Method for its own shares and Discounted Cash Flow Method for valuing the subsidiary, is within the provisions of Rule 11UA of the Income Tax Rules.
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