SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4897 
