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...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
ITAT ruled that for AY 2015-16 and 2016-17, the Assessing Officer (AO) incorrectly applied Rule 11UA in determining fair market value (FMV) of shares. The tribunal found that the rule requiring FMV of underlying assets was only applicable from AY 2018-19. The AO should have valued shares using book value as per the balance sheet for the relevant assessment years. The CIT(A)'s order deleting additions under section 56(2)(vii)(c) was upheld, and the revenue's appeal was dismissed, finding no procedural or substantive irregularities in the assessee's share acquisition and valuation.
ITAT ruled that for AY 2015-16 and 2016-17, the Assessing Officer (AO) incorrectly applied Rule 11UA in determining fair market value (FMV) of shares. The tribunal found that the rule requiring FMV of underlying assets was only applicable from AY 2018-19. The AO should have valued shares using book value as per the balance sheet for the relevant assessment years. The CIT(A)'s order deleting additions under section 56(2)(vii)(c) was upheld, and the revenue's appeal was dismissed, finding no procedural or substantive irregularities in the assessee's share acquisition and valuation.
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