Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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