Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
Under section 56(2)(viib), once an assessee adopts the prescribed DCF method under Rule 11UA for valuing unquoted equity shares, the Assessing Officer cannot discard that valuation merely because subsequent actual results differ from the original projections. The Tribunal noted that DCF valuation is inherently projection-based and cannot be reworked by substituting later actual figures, nor can the Officer switch to NAV valuation when that method was not chosen by the assessee. As the assessee relied on a qualified valuation report and the Revenue showed no cogent material of perversity, the share premium addition was deleted and the appeal was allowed.
Under section 56(2)(viib), once an assessee adopts the prescribed DCF method under Rule 11UA for valuing unquoted equity shares, the Assessing Officer cannot discard that valuation merely because subsequent actual results differ from the original projections. The Tribunal noted that DCF valuation is inherently projection-based and cannot be reworked by substituting later actual figures, nor can the Officer switch to NAV valuation when that method was not chosen by the assessee. As the assessee relied on a qualified valuation report and the Revenue showed no cogent material of perversity, the share premium addition was deleted and the appeal was allowed.
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