Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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