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The ITAT affirmed the CIT(A)'s determination, rejecting the TPO's transfer pricing adjustment that valued shares at a higher rate on account of a premium paid by the assessee to its associated enterprise (AE). Relying on authoritative high court precedents and subsequent CBDT instruction, the Tribunal held the premium constituted a capital account transaction and did not amount to taxable income of the assessee. Consequently, the TP adjustment was annulled and the appeal by the revenue dismissed. The assessment order was set aside insofar as it enhanced income by treating the share premium as taxable, with the CIT(A) order upheld.
The ITAT affirmed the CIT(A)'s determination, rejecting the TPO's transfer pricing adjustment that valued shares at a higher rate on account of a premium paid by the assessee to its associated enterprise (AE). Relying on authoritative high court precedents and subsequent CBDT instruction, the Tribunal held the premium constituted a capital account transaction and did not amount to taxable income of the assessee. Consequently, the TP adjustment was annulled and the appeal by the revenue dismissed. The assessment order was set aside insofar as it enhanced income by treating the share premium as taxable, with the CIT(A) order upheld.
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