Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
ITAT deleted the addition in the firm's hands for partners' capital contribution under section 68, holding that once the firm furnished the source of capital and the partners confirmed the contribution, its onus stood discharged; any further inquiry into creditworthiness had to be made against the partners, not the firm. On unsecured loans from two creditors, the Tribunal found the assessee's version of banking-channel receipts and later repayment with interest required verification of bank entries and repayment evidence. That issue was remanded to the Assessing Officer for fresh adjudication, with no addition indicated if repayment was established. The appeal was thus allowed for statistical purposes.
ITAT deleted the addition in the firm's hands for partners' capital contribution under section 68, holding that once the firm furnished the source of capital and the partners confirmed the contribution, its onus stood discharged; any further inquiry into creditworthiness had to be made against the partners, not the firm. On unsecured loans from two creditors, the Tribunal found the assessee's version of banking-channel receipts and later repayment with interest required verification of bank entries and repayment evidence. That issue was remanded to the Assessing Officer for fresh adjudication, with no addition indicated if repayment was established. The appeal was thus allowed for statistical purposes.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4801
Join Channel
TaxTMI 
