Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Addition u/s 56(2)(viib) - Method of valuation of shares - closely held company issues its shares at a premium - The tribunal sided with the assessee, affirming the FMV as per the Discounted Cash Flow (DCF) method. It held that when the law provides for a valuation method and the assessee chooses one of the prescribed methods, the AO cannot disregard the assessee's valuation without substantial grounds. The tribunal referenced multiple judgments supporting the assessee's right to choose between the Net Asset Value (NAV) method and the DCF method for valuation.
Addition u/s 56(2)(viib) - Method of valuation of shares - closely held company issues its shares at a premium - The tribunal sided with the assessee, affirming the FMV as per the Discounted Cash Flow (DCF) method. It held that when the law provides for a valuation method and the assessee chooses one of the prescribed methods, the AO cannot disregard the assessee's valuation without substantial grounds. The tribunal referenced multiple judgments supporting the assessee's right to choose between the Net Asset Value (NAV) method and the DCF method for valuation.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
