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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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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