https://www.taxtmi.com/caselaws?id=792989 Section 56(2)(viib) was held inapplicable to a bona fide intra-group CCPS issue and conversion supported by expert DCF valuation; the tax authorities could test the valuation for patent defects but could not replace it with NAV merely because they preferred a different method or because later actuals diverged from projections, so the addition was deleted. The management fee reversal required documentary verification of the year-end true-up mechanism, so the matter was remitted for fresh adjudication. Payments to MTH were treated as revenue in nature because the arrangement was for transformation and related services, with no acquisition of an enduring capital asset; the ad hoc disallowance was therefore not sustained. en-us Thu, 04 Jun 2026 00:00:00 +0530 Sat, 06 Jun 2026 08:42:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792989 Section 56(2)(viib) was held inapplicable to a bona fide intra-group CCPS issue and conversion supported by expert DCF valuation; the tax authorities could test the valuation for patent defects but could not replace it with NAV merely because they preferred a different method or because later actuals diverged from projections, so the addition was deleted. The management fee reversal required documentary verification of the year-end true-up mechanism, so the matter was remitted for fresh adjudication. Payments to MTH were treated as revenue in nature because the arrangement was for transformation and related services, with no acquisition of an enduring capital asset; the ad hoc disallowance was therefore not sustained. Case-Laws Income Tax Thu, 04 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792989