Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability ...
Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
Section 80P deduction for co-operative societies remains available despite nominal members and housing society status, with limited interest income tr...
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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