Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
Section 7 admission requires established financial debt and default, not precise interest quantification, while post-suspension defaults remain action...
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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