Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
Revision u/s 263 - issue of shares at premium - The Tribunal affirmed the PCIT's findings regarding the inadequacy of the AO's examination of the valuation of CCDs. It concluded that there was no error in discrediting the valuation method adopted by the appellant. - Despite the appellant's contentions regarding jurisdictional matters, the Tribunal upheld the validity of the orders passed by the PCIT and AO. - The Tribunal agreed with the AO's application of section 56(2)(viib) and the rejection of the DCF method, thereby affirming the addition made to the appellant's income.
Revision u/s 263 - issue of shares at premium - The Tribunal affirmed the PCIT's findings regarding the inadequacy of the AO's examination of the valuation of CCDs. It concluded that there was no error in discrediting the valuation method adopted by the appellant. - Despite the appellant's contentions regarding jurisdictional matters, the Tribunal upheld the validity of the orders passed by the PCIT and AO. - The Tribunal agreed with the AO's application of section 56(2)(viib) and the rejection of the DCF method, thereby affirming the addition made to the appellant's income.
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