Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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In this ITAT ruling, the Tribunal held that the DCF method for share valuation was validly applied per Rule 11UA(2)(b), accepting the Chartered Accountant's certification of fair market value at Rs. 106 per share. The AO's attempts to find discrepancies in the CA's report were deemed improper as they lacked basis in acceptable principles or approved standards. The Tribunal determined that valuation can only be disputed by another legally recognized expert, thus the s.56(2)(viib) addition was erroneous. Regarding the s.68 addition, the Tribunal ruled that the proviso only permits scrutiny of immediate subscribing companies, not secondary funding sources. The s.14A disallowance was upheld as the assessee failed to rebut findings about expenditure incurred for earning dividend income.
In this ITAT ruling, the Tribunal held that the DCF method for share valuation was validly applied per Rule 11UA(2)(b), accepting the Chartered Accountant's certification of fair market value at Rs. 106 per share. The AO's attempts to find discrepancies in the CA's report were deemed improper as they lacked basis in acceptable principles or approved standards. The Tribunal determined that valuation can only be disputed by another legally recognized expert, thus the s.56(2)(viib) addition was erroneous. Regarding the s.68 addition, the Tribunal ruled that the proviso only permits scrutiny of immediate subscribing companies, not secondary funding sources. The s.14A disallowance was upheld as the assessee failed to rebut findings about expenditure incurred for earning dividend income.
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