Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
Revision u/s 263 - 56(2)(x)(c)(B) - FMV purchases exceeds the price of shares - The tribunal observed that, the option to adopt either NAV or DCF Method for valuing the shares has been given to an Assessee in the statute itself. When the A.O. has appreciated this option availed by the Assessee, his order cannot be construed as erroneous. - Further, it is observed that it is not a case wherein the Assessing Officer failed to conduct enquiry rather it is the case wherein the AO has conducted an elaborate enquiry and adopted one of the two views which was plausible view. - Consequently, the ITAT following the decision of Supreme Court, quashed the revision order.
Revision u/s 263 - 56(2)(x)(c)(B) - FMV purchases exceeds the price of shares - The tribunal observed that, the option to adopt either NAV or DCF Method for valuing the shares has been given to an Assessee in the statute itself. When the A.O. has appreciated this option availed by the Assessee, his order cannot be construed as erroneous. - Further, it is observed that it is not a case wherein the Assessing Officer failed to conduct enquiry rather it is the case wherein the AO has conducted an elaborate enquiry and adopted one of the two views which was plausible view. - Consequently, the ITAT following the decision of Supreme Court, quashed the revision order.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4807 
Join Channel 
