Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
AO cannot interfere in assessee's chosen valuation method u/s 56(2)(viib). AO exceeded jurisdiction by rejecting DCF method and applying NAV method. Transaction between independent parties at Rs. 13.94 per share accepted under FEMA and RBI guidelines. Same value adopted by assessee cannot be disturbed for share issue. Addition u/s 56(2)(viib) deleted. Assessee's appeal allowed.
AO cannot interfere in assessee's chosen valuation method u/s 56(2)(viib). AO exceeded jurisdiction by rejecting DCF method and applying NAV method. Transaction between independent parties at Rs. 13.94 per share accepted under FEMA and RBI guidelines. Same value adopted by assessee cannot be disturbed for share issue. Addition u/s 56(2)(viib) deleted. Assessee's appeal allowed.
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