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...
ITAT ruled in favor of the appellant regarding share capital additions under Section 68. The tribunal found that since cash receipts and corresponding credits occurred in the previous assessment year, no additions could be made in the current year based on share allotment. For AY 2017-18, the issuance of 1,50,000 shares to A Co. was deemed legitimate as the company demonstrated sufficient operational revenue (Rs. 15.49 Cr), trading activities, and adequate shareholder funds. The shares were issued at the same premium rate as existing shareholders, supported by a Rule 11UA valuation report. The appellant satisfied all requirements under Section 68, establishing the nature and source of share capital. The appeal was allowed, reversing the AO's additions.
ITAT ruled in favor of the appellant regarding share capital additions under Section 68. The tribunal found that since cash receipts and corresponding credits occurred in the previous assessment year, no additions could be made in the current year based on share allotment. For AY 2017-18, the issuance of 1,50,000 shares to A Co. was deemed legitimate as the company demonstrated sufficient operational revenue (Rs. 15.49 Cr), trading activities, and adequate shareholder funds. The shares were issued at the same premium rate as existing shareholders, supported by a Rule 11UA valuation report. The appellant satisfied all requirements under Section 68, establishing the nature and source of share capital. The appeal was allowed, reversing the AO's additions.
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