Customs Broker association membership becomes mandatory in the operating jurisdiction, with exclusive membership and limited compliance-time relaxatio...
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...
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AO rejected DCF method for valuation of shares issued as rights issue to existing shareholders. Instead, AO applied NAV method u/r 11UA determining FMV at Rs.3.07 per share and made addition u/s 56(2)(viib). ITAT held DCF is recognized valuation method based on future projections considering various factors. AO cannot tinker with DCF method adopted by assessee and apply NAV method. When law provides two methods, AO cannot reject one method for another without substantial reasons. Following Cinestaan, DCF valuation by assessee accepted. No addition u/s 56(2)(viib) upheld. Regarding addition u/s 68, assessee companies had sufficient reserves, revenue, borrowings to explain source. Onus of proving source discharged. Addition u/s 68 deleted. Assessee's appeal allowed.
AO rejected DCF method for valuation of shares issued as rights issue to existing shareholders. Instead, AO applied NAV method u/r 11UA determining FMV at Rs.3.07 per share and made addition u/s 56(2)(viib). ITAT held DCF is recognized valuation method based on future projections considering various factors. AO cannot tinker with DCF method adopted by assessee and apply NAV method. When law provides two methods, AO cannot reject one method for another without substantial reasons. Following Cinestaan, DCF valuation by assessee accepted. No addition u/s 56(2)(viib) upheld. Regarding addition u/s 68, assessee companies had sufficient reserves, revenue, borrowings to explain source. Onus of proving source discharged. Addition u/s 68 deleted. Assessee's appeal allowed.
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