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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
The ITAT considered an appeal regarding addition u/s 56(2)(viib) concerning the valuation of preference shares. The Assessee lacked a valuation report supporting the method used to determine the value of preference shares. The Tribunal held that unquoted redeemable preference shares should be valued u/s 11UA(1)(c)(c) with a mandatory merchant banker or accountant's report. The AO erred in applying the wrong rule. Valuation reports are considered statutory evidence and must be presumed correct unless proven otherwise. The burden is on the AO to rebut the report with evidence of incorrect facts or methodology. The CIT(A) found the valuation report sufficient, dismissing the Revenue's appeal.
The ITAT considered an appeal regarding addition u/s 56(2)(viib) concerning the valuation of preference shares. The Assessee lacked a valuation report supporting the method used to determine the value of preference shares. The Tribunal held that unquoted redeemable preference shares should be valued u/s 11UA(1)(c)(c) with a mandatory merchant banker or accountant's report. The AO erred in applying the wrong rule. Valuation reports are considered statutory evidence and must be presumed correct unless proven otherwise. The burden is on the AO to rebut the report with evidence of incorrect facts or methodology. The CIT(A) found the valuation report sufficient, dismissing the Revenue's appeal.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
