Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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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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