Constitutional personal-liberty safeguards limit PMLA twin bail conditions where completed investigations lead to prolonged incarceration before trial...
Automated airline software subscriptions without human intervention fail technical-services characterisation and do not make available underlying tech...
Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
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Rule 11UA(2) permits an assessee issuing unquoted equity shares to choose either the Discounted Cash Flow or Net Asset Value method for determining fair market value under section 56(2)(viib). After a prescribed method is chosen, the Assessing Officer may scrutinise the valuation report but cannot replace it with a formula-based valuation merely because projections, management inputs, or standard disclaimers are questioned. Discounted Cash Flow projections cannot be rejected solely by comparison with subsequent performance. Rejection requires demonstrably incorrect data, a wholly erroneous basis, or a wrong valuation approach; absent such defects, the chosen method governs share-premium valuation.
Rule 11UA(2) permits an assessee issuing unquoted equity shares to choose either the Discounted Cash Flow or Net Asset Value method for determining fair market value under section 56(2)(viib). After a prescribed method is chosen, the Assessing Officer may scrutinise the valuation report but cannot replace it with a formula-based valuation merely because projections, management inputs, or standard disclaimers are questioned. Discounted Cash Flow projections cannot be rejected solely by comparison with subsequent performance. Rejection requires demonstrably incorrect data, a wholly erroneous basis, or a wrong valuation approach; absent such defects, the chosen method governs share-premium valuation.
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