Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
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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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