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Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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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