Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
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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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