Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding


  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights March 2023 Year 2023 This

TP Adjustment - Fair market value of share of ECL representing ...

Income Tax

March 4, 2023

TP Adjustment - Fair market value of share of ECL representing the ALP - the DCF Method could not be adopted in the facts and circumstances of the present case as the Appellant is an investment company incorporated on 30.01.2007 with unpredictable income/cash flows. This takes us to the method adopted by the Appellant for determining the value of shares of ECL - Rule 11UA is also based on Net Asset Value Approach adopted in the valuation report relied upon by the Appellant to support the valuation of shares of ECL - Valuation done by the assessee adopted - AT

View Source

 


 

You may also like:

  1. 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...

  2. Addition u/s 68 or 56(2) - Unexplained cash credit u/s 68 - share transactions - the valuation aspect of the shares is made on the Discounted cash flow method (DCF) and...

  3. Transfer pricing adjustment deleted - the comparables adopted by the assessee are uncontrolled parties and can be considered for the purpose of determining the Arms'...

  4. Addition u/s 56(2)(viib) - excessive share premium - determination of the FMV of the shares [unquoted equity] - As per the mandate of law, the option to determine the...

  5. 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...

  6. Addition u/s. 56(2)(viib) - differential value of shares - It is the prerogative and privilege of the assessee to adopt one method and once the assessee has chosen...

  7. Transfer pricing adjustment - The provisions were not incorporated to make adjustment at any cost and ignoring the basic facts - No adjustment to be made if transaction...

  8. Addition u/s. 56[2] [viib] - method for valuation of the shares - equity and preference shares allotted by assessee to various residents at a premium - Discounted Cash...

  9. TPA - ALP determination - Without complying to the statutory provisions, the Transfer Pricing Officer certainly cannot determine the arm's length price on ad-hoc /...

  10. Transfer Pricing adjustments - Arms length price (ALP) - u/s 92CA - software development and IT enabled services - selection of comparable - Size matters in business

 

Quick Updates:Latest Updates