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...
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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