Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
ITAT held the assessee failed to justify share valuation under Sec. 56(2)(viib), as the submitted valuation report omitted loan liabilities. CIT(A)'s direction for valuation from two valuers at assessee's option while restricting AO's scope was deemed unjustified. The DCF-based valuation was questioned due to lack of business activities in subsequent years. Following precedent from Madras HC, ITAT remanded the matter back to AO for fresh determination of share FMV, as the original fact-finding exercise was incomplete. The valuation must consider all liabilities and actual business performance. Appeal allowed for statistical purposes, directing AO to conduct comprehensive share valuation under Sec. 56(2)(viib).
ITAT held the assessee failed to justify share valuation under Sec. 56(2)(viib), as the submitted valuation report omitted loan liabilities. CIT(A)'s direction for valuation from two valuers at assessee's option while restricting AO's scope was deemed unjustified. The DCF-based valuation was questioned due to lack of business activities in subsequent years. Following precedent from Madras HC, ITAT remanded the matter back to AO for fresh determination of share FMV, as the original fact-finding exercise was incomplete. The valuation must consider all liabilities and actual business performance. Appeal allowed for statistical purposes, directing AO to conduct comprehensive share valuation under Sec. 56(2)(viib).
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TaxTMI 
TaxTMI 
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