Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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