Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
ITAT affirmed CIT(A) and dismissed the revenue's appeal, holding that under Rule 11UA(2) the assessee had statutory option to adopt either NAV or DCF for valuation of unquoted equity shares for s.56(2)(viib); once the assessee validly exercised the option and furnished a merchant banker's DCF valuation, the AO lacked jurisdiction to unilaterally alter the valuation method. The AO's rejection of the valuation without obtaining an alternative valuation from an authorized valuer under Rule 11UA(2) was impermissible. Absent any admissible contrary valuation, the addition was correctly deleted and the assessment adjustment was reversed in favour of the assessee; appeal by the revenue dismissed.
ITAT affirmed CIT(A) and dismissed the revenue's appeal, holding that under Rule 11UA(2) the assessee had statutory option to adopt either NAV or DCF for valuation of unquoted equity shares for s.56(2)(viib); once the assessee validly exercised the option and furnished a merchant banker's DCF valuation, the AO lacked jurisdiction to unilaterally alter the valuation method. The AO's rejection of the valuation without obtaining an alternative valuation from an authorized valuer under Rule 11UA(2) was impermissible. Absent any admissible contrary valuation, the addition was correctly deleted and the assessment adjustment was reversed in favour of the assessee; appeal by the revenue dismissed.
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TaxTMI 
TaxTMI 
of 4918 
