Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Shares allotted at premium based on valuation report following DCF method. AO rejected report without pointing errors. ITAT held valuation not an exact science, cannot be done with arithmetic precision. Shares subscribed by outside investor, a reputed corporate group, not a related party. Hence, no infirmity in CIT(A) order deleting addition u/s 56(2)(viib). Disallowance u/s 36(1)(iii) on interest expenditure deleted by CIT(A) as zero coupon debentures were consideration for transfer of assets, not investment. ITAT upheld CIT(A)'s view. Interest-free deposit given had sufficient own funds, no disallowance u/s 36(1)(iii) warranted as per Bombay High Court ruling. Assessee's appeal allowed on this issue.
Shares allotted at premium based on valuation report following DCF method. AO rejected report without pointing errors. ITAT held valuation not an exact science, cannot be done with arithmetic precision. Shares subscribed by outside investor, a reputed corporate group, not a related party. Hence, no infirmity in CIT(A) order deleting addition u/s 56(2)(viib). Disallowance u/s 36(1)(iii) on interest expenditure deleted by CIT(A) as zero coupon debentures were consideration for transfer of assets, not investment. ITAT upheld CIT(A)'s view. Interest-free deposit given had sufficient own funds, no disallowance u/s 36(1)(iii) warranted as per Bombay High Court ruling. Assessee's appeal allowed on this issue.
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