Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4827 
Join Channel 
