Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
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Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
ITAT held that the AO's rejection of the assessee's DCF valuation under s.56(2)(viib) read with r.11UA was impermissible absent pinpointing of specific errors; the DCF methodology adopted by the assessee was a permissible valuation and cannot be supplanted by AO's unsupported conclusion. The Tribunal further held that where substantial subscriptions emanated from a non-resident subscriber, s.56(2)(viib) could not sustain additions in respect of those subscriptions. AO's subsequent addition under s.68 was unsustainable because AO did not challenge identity, genuineness or creditworthiness nor discharge the onus to disprove the assessee's explanation. The Tribunal deleted the addition of Rs.60,06,500 and allowed the grounds.
ITAT held that the AO's rejection of the assessee's DCF valuation under s.56(2)(viib) read with r.11UA was impermissible absent pinpointing of specific errors; the DCF methodology adopted by the assessee was a permissible valuation and cannot be supplanted by AO's unsupported conclusion. The Tribunal further held that where substantial subscriptions emanated from a non-resident subscriber, s.56(2)(viib) could not sustain additions in respect of those subscriptions. AO's subsequent addition under s.68 was unsustainable because AO did not challenge identity, genuineness or creditworthiness nor discharge the onus to disprove the assessee's explanation. The Tribunal deleted the addition of Rs.60,06,500 and allowed the grounds.
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