Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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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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