Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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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