Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
The ITAT held that the AO failed to conclusively establish that the investing companies were non-existent to invoke Section 68 for addition of share capital. Regarding Section 56(2)(viib) addition for share premium, the ITAT ruled that when an unquoted company opts for the Discounted Cash Flow valuation method u/r 11UA(2)(b), the AO cannot disregard it and substitute with another method, even if discrepancies exist in the assessee's workings. The assessee's appeal was allowed.
The ITAT held that the AO failed to conclusively establish that the investing companies were non-existent to invoke Section 68 for addition of share capital. Regarding Section 56(2)(viib) addition for share premium, the ITAT ruled that when an unquoted company opts for the Discounted Cash Flow valuation method u/r 11UA(2)(b), the AO cannot disregard it and substitute with another method, even if discrepancies exist in the assessee's workings. The assessee's appeal was allowed.
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