Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
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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