Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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...
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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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