Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
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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