Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
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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