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...
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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