Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
Cooperative society deposits, member-interest TDS exemption and credit-facility deduction claims require verification through records and supporting e...
Customs jurisdiction over EPCG condition breaches survives export-obligation discharge certificates, requiring alleged fraud and misdeclaration to be ...
Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
Revision u/s 263 - Disallowance of STCG - FMV determination of shares - The Appellate Tribunal (AT) scrutinized the fair market value and share valuation process, concluding that the appellant failed to substantiate their claims adequately. They found discrepancies in the valuation and affirmed the PCIT's decision to reject the appellant's arguments. The AT affirmed the PCIT's characterization of the transactions as structured and not at arm's length. They concluded that the assessment order was prejudicial to the interest of the Revenue and upheld the PCIT's decision to set it aside.
Revision u/s 263 - Disallowance of STCG - FMV determination of shares - The Appellate Tribunal (AT) scrutinized the fair market value and share valuation process, concluding that the appellant failed to substantiate their claims adequately. They found discrepancies in the valuation and affirmed the PCIT's decision to reject the appellant's arguments. The AT affirmed the PCIT's characterization of the transactions as structured and not at arm's length. They concluded that the assessment order was prejudicial to the interest of the Revenue and upheld the PCIT's decision to set it aside.
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