Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Amends the Pre Pack regulations to redefine "fair value" as the estimated realizable value of the corporate debtor or its assets on the insolvency commencement date, computed after marketing and including tangible, intangible assets and underlying synergies. Requires appointment of two sets of registered valuers, each set comprising one valuer per asset class with a coordinating valuer. Prescribes a process: valuers to explain methodology to the committee, conduct physical verification, submit asset level fair and liquidation values to coordinating valuers, which compute set fair values considering synergies; the fair value of the corporate debtor is the average of the two coordinating valuer estimates and liquidation value is the asset class averages. Valuation reports must follow Board notified formats.
Amends the Pre Pack regulations to redefine "fair value" as the estimated realizable value of the corporate debtor or its assets on the insolvency commencement date, computed after marketing and including tangible, intangible assets and underlying synergies. Requires appointment of two sets of registered valuers, each set comprising one valuer per asset class with a coordinating valuer. Prescribes a process: valuers to explain methodology to the committee, conduct physical verification, submit asset level fair and liquidation values to coordinating valuers, which compute set fair values considering synergies; the fair value of the corporate debtor is the average of the two coordinating valuer estimates and liquidation value is the asset class averages. Valuation reports must follow Board notified formats.
Note: It is a system-generated summary and is for quick reference only.