Preliminary reassessment proceedings generally require statutory remedies unless jurisdiction is wholly absent or mandatory conditions are patently br...
Agricultural land classification requires cumulative factual indicators, while industrial-purpose land and absent agricultural use defeat reinvestment...
Composite residential flat exemption upheld where supplementary agreement merged adjoining units and additional evidence supported the taxpayer's inve...
Shares allotted to holding company by wholly owned subsidiary. Discounted Cash Flow (DCF) method adopted for valuing Compulsory Convertible Preference Shares (CCPS) is legitimate as per Rule 11UA. Assessing Officer cannot reject prescribed valuation method. Reliance on subsequent financial losses to question valuation is misplaced; projections must be assessed based on facts at the time of valuation, not future outcomes. Transaction between wholly owned subsidiary and holding company does not create unaccounted income or inflated share value for tax evasion unless specifically proved. Addition u/s 56(2)(viib) deleted. Revenue's appeal dismissed.
Shares allotted to holding company by wholly owned subsidiary. Discounted Cash Flow (DCF) method adopted for valuing Compulsory Convertible Preference Shares (CCPS) is legitimate as per Rule 11UA. Assessing Officer cannot reject prescribed valuation method. Reliance on subsequent financial losses to question valuation is misplaced; projections must be assessed based on facts at the time of valuation, not future outcomes. Transaction between wholly owned subsidiary and holding company does not create unaccounted income or inflated share value for tax evasion unless specifically proved. Addition u/s 56(2)(viib) deleted. Revenue's appeal dismissed.
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