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1. Income from other sources u/s 56(2)(viib) - determining the share value of the premium - Method of valuation of shares - AO did not point out any flaw in the method of...

2. Addition u/s 56(2)(viib) - Method of valuation of shares - closely held company issues its shares at a premium - The tribunal sided with the assessee, affirming the FMV...

3. TP adjustment - ALP determination - Selection or change in Most Appropriate Method (MAM) - “Other Method" v/s "CUP Method" - Assessee can resile from the most...

4. Addition u/s.56(2)(vii)(b) - share premium - difference between the issue price and the actual share price determined by the AO - AO has changed the method of valuation...

5. TP adjustment - MAM selection - method used for benchmarking the royalty transaction - It may be true that the assessee aggregated payment of royalty with the...

6. Rejection of Books of accounts - Method of accounting - Percentage completion method or project completion method - recognition/identification of income under the 1961...

7. TP Adjustment - selection of most appropriate method (MAM) - Resale Price Method or Transactional Net Margin Method - Introduction of Fresh Comparables - Removal of 3%...

8. TP adjustment - royalty paid by the assessee to its AE - selection of MAM - The method of the assessee can be pigeonholed in the “other method” provided in Rule 10AB r.w....

9. TP Adjustment - 'arranged' pricing' - TNMM method or CUP method - the superiority of any particular method to arrive at the ALP is ruled out.The TNMM (Transactional Net...

10. TP Adjustment - ALP is determined by TPO by not applying any method at all or by choosing a method which is not prescribed u/s.92C(1) of the Act, then such a...

11. Addition u/s 56 (2) (viib) - issue of shares that exceeds the face value - Both these methods have different approaches and methodologies therefore there are bound to be...

12. Difference in method of accounting adopted - EMI method to account the finance charges for the income tax purposes and SOD Method to arrive at balance sheet and profit...

13. Addition u/s 56 - Issue of shares at premium - The ITAT recognizes that the holding company's value is directly impacted by the performance of its subsidiary and...

14. Valuation of imported goods - The applicant's proposed valuation method, Transfer Pricing System and Steering Concept (TPuS) method also known as Resale Price...

15. Valuation of shares at a premium u/s 56(2)(viib) - Keeping in view that DCF is correct method of determining the FMV of the unquoted shares, the assessee has option to...