Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
For section 50CA, valuation of unquoted equity shares must follow Rule 11UAA read with Rule 11UA(1), and the Assessing Officer could not insist on a merchant banker report by importing the regime meant for section 56(2)(viib). The assessee's Chartered Accountant valuation under the Net Asset Value method showed a fair market value below the actual sale price, so the declared consideration could not be substituted merely because fresh shares had earlier been issued to the same buyer at a higher price. The ITAT upheld deletion of the addition, finding no basis for an adjustment under section 50CA.
For section 50CA, valuation of unquoted equity shares must follow Rule 11UAA read with Rule 11UA(1), and the Assessing Officer could not insist on a merchant banker report by importing the regime meant for section 56(2)(viib). The assessee's Chartered Accountant valuation under the Net Asset Value method showed a fair market value below the actual sale price, so the declared consideration could not be substituted merely because fresh shares had earlier been issued to the same buyer at a higher price. The ITAT upheld deletion of the addition, finding no basis for an adjustment under section 50CA.
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