Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
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ITAT upheld the reopening u/s 147 and sustained the addition u/s 56(2)(vii)(b) treating excess share premium as taxable consideration. The Tribunal found the Chartered Accountant's DCF certificate defective and unreliable-projections were unverified, optimistic, and inconsistent with actual performance-thereby justifying the AO's rejection of the DCF method. Applying the NAV method, the AO's FMV determination (Rs.10 per share) was upheld as reasonable in light of the valuer's failure to follow ICAI guidance and to furnish requisite cash-flow, discount-rate and terminal-value analyses. The CIT(A)'s conclusions were affirmed and the assessee's appeal dismissed.
ITAT upheld the reopening u/s 147 and sustained the addition u/s 56(2)(vii)(b) treating excess share premium as taxable consideration. The Tribunal found the Chartered Accountant's DCF certificate defective and unreliable-projections were unverified, optimistic, and inconsistent with actual performance-thereby justifying the AO's rejection of the DCF method. Applying the NAV method, the AO's FMV determination (Rs.10 per share) was upheld as reasonable in light of the valuer's failure to follow ICAI guidance and to furnish requisite cash-flow, discount-rate and terminal-value analyses. The CIT(A)'s conclusions were affirmed and the assessee's appeal dismissed.
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