International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
Enhancement made by the Ld. CIT(A) u/s 251(1) r.w.s. 56(2) (viib) - AO substituted fair market value determined by the assessee through his own valuation - Assessees have submitted the Valuation Report duly signed by the auditor by following NAV/DCF Method as required under Rule 11UA(2) of the Rules - The Tribunal disagreed with this decision, highlighting that the assessee had provided a valuation report as per the prescribed method (Discounted Cash Flow Method under Rule 11UA(2)(b)). The Tribunal found that the lower authorities had inappropriately rejected this valuation report without providing a basis for doing so.
Enhancement made by the Ld. CIT(A) u/s 251(1) r.w.s. 56(2) (viib) - AO substituted fair market value determined by the assessee through his own valuation - Assessees have submitted the Valuation Report duly signed by the auditor by following NAV/DCF Method as required under Rule 11UA(2) of the Rules - The Tribunal disagreed with this decision, highlighting that the assessee had provided a valuation report as per the prescribed method (Discounted Cash Flow Method under Rule 11UA(2)(b)). The Tribunal found that the lower authorities had inappropriately rejected this valuation report without providing a basis for doing so.
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