Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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ITAT applied the real income theory to hold that alleged bonus or commission receivable could not be taxed on a due basis where there was no proof of receipt, no employer provisioning, and no document showing a legal right to receive the amount; the deletion of that addition was upheld. On the unexplained money issue, the Tribunal accepted third-party confirmations, agreements, revenue records and section 133(6) responses admitting cash handed over for proposed land transactions, and directed deletion of Rs. 85,00,000. For the remaining cash addition, it held that bare assertions of cash savings and business receipts were insufficient without corroboration, so the relief already granted by the first appellate authority was sustained and no further interference was warranted.
ITAT applied the real income theory to hold that alleged bonus or commission receivable could not be taxed on a due basis where there was no proof of receipt, no employer provisioning, and no document showing a legal right to receive the amount; the deletion of that addition was upheld. On the unexplained money issue, the Tribunal accepted third-party confirmations, agreements, revenue records and section 133(6) responses admitting cash handed over for proposed land transactions, and directed deletion of Rs. 85,00,000. For the remaining cash addition, it held that bare assertions of cash savings and business receipts were insufficient without corroboration, so the relief already granted by the first appellate authority was sustained and no further interference was warranted.
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