Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
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Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Addition u/s 56(2)(viia) - purchase of shares at price more than its fair market value - The tribunal extensively reviewed the submissions and evidence presented, including the valuation of shares, the authenticity of transactions, and the procedural challenges raised by the assessee. The AO added sums to the assessee's income as the purchase price of shares in several companies was found to be less than their fair market value as per the records on the Ministry of Corporate Affairs website. The ITAT agreed with this approach, rejecting the assessee's valuation reports which claimed lower market values for these shares.
Addition u/s 56(2)(viia) - purchase of shares at price more than its fair market value - The tribunal extensively reviewed the submissions and evidence presented, including the valuation of shares, the authenticity of transactions, and the procedural challenges raised by the assessee. The AO added sums to the assessee's income as the purchase price of shares in several companies was found to be less than their fair market value as per the records on the Ministry of Corporate Affairs website. The ITAT agreed with this approach, rejecting the assessee's valuation reports which claimed lower market values for these shares.
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