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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HC upheld ITAT's order, affirming the Assessee's valuation of unquoted equity shares using Discounted Cash Flow (DCF) method under Rule 11UA(2). The court found the Chartered Accountant's valuation report valid, noting that general disclaimers do not invalidate the expert's assessment. The Assessing Officer's rejection of the valuation was deemed inappropriate without identifying specific material errors in the underlying data. The ICAI Valuation Standard 301 supports the DCF method for subsidiary investment valuation. Consequently, the addition under section 56(2)(viib) was deleted, with no substantial questions of law arising from the case.
HC upheld ITAT's order, affirming the Assessee's valuation of unquoted equity shares using Discounted Cash Flow (DCF) method under Rule 11UA(2). The court found the Chartered Accountant's valuation report valid, noting that general disclaimers do not invalidate the expert's assessment. The Assessing Officer's rejection of the valuation was deemed inappropriate without identifying specific material errors in the underlying data. The ICAI Valuation Standard 301 supports the DCF method for subsidiary investment valuation. Consequently, the addition under section 56(2)(viib) was deleted, with no substantial questions of law arising from the case.
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