Independent show-cause notices remain separate proceedings, while customs adjudication challenges should ordinarily follow the statutory appellate rem...
Institutional incapacity in customs settlement proceedings excludes non-functional quorum periods from statutory disposal timelines, preventing automa...
Interactive touchscreen panels with integrated computing functions fall under automatic data-processing machines rather than display monitors for cust...
Ex parte injunction service requirements were substantially met, while civil recovery and SFIO investigation into provident fund defalcation continued...
Enforcement of resolution-plan directions continues without a Supreme Court stay, preventing suspension of redistribution and escrowed-fund distributi...
Third-party ownership claims over attached property require Special Court adjudication where purchasers lack registered sale deeds and bona fides rema...
Pure-agent reimbursements in clearing and forwarding services are excluded from taxable value when qualifying third-party payments are properly record...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4786
Join Channel
TaxTMI 
