Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
ITAT upheld the appellate authority's decision and dismissed the Revenue's appeal, holding that once the assessee validly elected an approved valuation methodology under Rule 11UA/section 56(2)(viib) (here, the DCF/DFC F method), the Assessing Officer lacked jurisdiction to substitute an alternative approved method (NAV) or re-determine fair market value. The Tribunal found the AO's rejection of the registered valuer's DCF-based valuation and his comparison of projected figures with subsequent actuals impermissible, recognising valuation as a technical exercise for experts and noting investor acceptance of the valuation supported its reasonableness. Consequently the CIT(A)'s findings were affirmed and the addition was deleted.
ITAT upheld the appellate authority's decision and dismissed the Revenue's appeal, holding that once the assessee validly elected an approved valuation methodology under Rule 11UA/section 56(2)(viib) (here, the DCF/DFC F method), the Assessing Officer lacked jurisdiction to substitute an alternative approved method (NAV) or re-determine fair market value. The Tribunal found the AO's rejection of the registered valuer's DCF-based valuation and his comparison of projected figures with subsequent actuals impermissible, recognising valuation as a technical exercise for experts and noting investor acceptance of the valuation supported its reasonableness. Consequently the CIT(A)'s findings were affirmed and the addition was deleted.
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