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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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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