Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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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