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...
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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