Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
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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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