Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
Automotive radio classification treats integrated infotainment features as supplementary, placing complete and qualifying unassembled units under the ...
Separate corporate personality prevents directors from being personally liable for company deposits without a guarantee or independent legal undertaki...
Cross-segment derivatives manipulation: integrated order patterns can support interim restraints, while director liability requires responsibility, co...
Consequential assessment following revision directions was confined to verifying DCF share valuation and projection assumptions; because the directions did not require treating share premium as unexplained cash credit, the Section 68 addition was deleted. Where valuation exceeded fair market value, Section 56(2)(viib), subject to its conditions, was identified as the relevant provision. For AY 2014-15, the unamended Section 68 required proof of creditor identity, transaction genuineness and lender creditworthiness, not source of source. Generalised treatment of lender evidence required limited lender-wise verification, so the unsecured-loan addition was remanded without a merits determination.
Consequential assessment following revision directions was confined to verifying DCF share valuation and projection assumptions; because the directions did not require treating share premium as unexplained cash credit, the Section 68 addition was deleted. Where valuation exceeded fair market value, Section 56(2)(viib), subject to its conditions, was identified as the relevant provision. For AY 2014-15, the unamended Section 68 required proof of creditor identity, transaction genuineness and lender creditworthiness, not source of source. Generalised treatment of lender evidence required limited lender-wise verification, so the unsecured-loan addition was remanded without a merits determination.
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