Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Appellate Tribunal held that the Assessing Officer failed to provide findings for rejecting assessee's claim of exemption as a startup from applicability of section 56(2)(viib) regarding valuation of unquoted equity shares. Commissioner of Income Tax (Appeals) merely endorsed Assessing Officer's reasoning for not accepting valuation report without addressing assessee's claim. The issue was remanded to Assessing Officer to consider assessee's claim of startup exemption from section 56(2)(viib) after providing opportunity of hearing.
Appellate Tribunal held that the Assessing Officer failed to provide findings for rejecting assessee's claim of exemption as a startup from applicability of section 56(2)(viib) regarding valuation of unquoted equity shares. Commissioner of Income Tax (Appeals) merely endorsed Assessing Officer's reasoning for not accepting valuation report without addressing assessee's claim. The issue was remanded to Assessing Officer to consider assessee's claim of startup exemption from section 56(2)(viib) after providing opportunity of hearing.
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