Fair market value under section 50C must reflect existing property condition, not hypothetical development, and statutory valuation steps must be foll...
The Tribunal held that the onus was on the Revenue to demonstrate the Appellant's default leading to inordinate delay in allotment of shares, which the Revenue failed to discharge. Consequently, the transfer pricing adjustment treating share application money as an interest-free loan to the Associated Enterprise was deleted. Regarding the Dispute Resolution Panel's failure to consider the Assessing Officer's rectification order u/s 154 revising the income, the Assessing Officer was directed to recompute the income and tax liability after considering the rectification order. The Tribunal allowed the grounds raised by the Appellant on these issues.
The Tribunal held that the onus was on the Revenue to demonstrate the Appellant's default leading to inordinate delay in allotment of shares, which the Revenue failed to discharge. Consequently, the transfer pricing adjustment treating share application money as an interest-free loan to the Associated Enterprise was deleted. Regarding the Dispute Resolution Panel's failure to consider the Assessing Officer's rectification order u/s 154 revising the income, the Assessing Officer was directed to recompute the income and tax liability after considering the rectification order. The Tribunal allowed the grounds raised by the Appellant on these issues.
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