Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
In an unexplained cash credit dispute involving an alleged accommodation loan, the ITAT held that the assessee discharged the primary onus by producing confirmation, bank statements, income-tax records, balance sheet, loan agreement and the lender's NBFC certificate. As the transaction was routed through banking channels and repaid, and the AO neither rebutted the documents nor made an effective enquiry, the additions could not rest on suspicion or third-party information alone. The Tribunal also held that alleged non-payment of interest in a later year was irrelevant to the year under appeal. The additions under sections 68 and 69C were deleted.
In an unexplained cash credit dispute involving an alleged accommodation loan, the ITAT held that the assessee discharged the primary onus by producing confirmation, bank statements, income-tax records, balance sheet, loan agreement and the lender's NBFC certificate. As the transaction was routed through banking channels and repaid, and the AO neither rebutted the documents nor made an effective enquiry, the additions could not rest on suspicion or third-party information alone. The Tribunal also held that alleged non-payment of interest in a later year was irrelevant to the year under appeal. The additions under sections 68 and 69C were deleted.
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