Risk-based postal import clearance standardises electronic assessment, document requests, duty realisation and delivery controls at Foreign Post Offic...
Customs Cargo Service Provider appointment extends custodianship to additional terminal land, subject to cargo-control, security and licence condition...
Post-search scrutiny assessment remains available where original assessment limitation is unexpired, permitting timely completion under regular assess...
The ITAT held that u/s 56(2)(viib), addition on premium amount in excess of FMV for issuing Optional Convertible Preference Shares to holding company is unsustainable. The NAV method for valuation is valid only for equity shares, not OCPS. FMV based on equity shares for conversion is justified. Allotting shares to 100% holding company benefits existing shareholders, defeating the purpose of deeming provision u/s 56(2)(viib). CIT(A)'s decision is upheld as it aligns with law and facts. Revenue's appeal is dismissed.
The ITAT held that u/s 56(2)(viib), addition on premium amount in excess of FMV for issuing Optional Convertible Preference Shares to holding company is unsustainable. The NAV method for valuation is valid only for equity shares, not OCPS. FMV based on equity shares for conversion is justified. Allotting shares to 100% holding company benefits existing shareholders, defeating the purpose of deeming provision u/s 56(2)(viib). CIT(A)'s decision is upheld as it aligns with law and facts. Revenue's appeal is dismissed.
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