Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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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