Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Notional partners' capital entries credited as receivable under an LLP agreement were held outside section 68 because there was no actual inflow of funds during the year, the entries were only book adjustments, and the partners' identities and creditworthiness were not materially disputed; the addition was deleted. Administrative expenditure was also allowed because the LLP had already been set up through execution of the agreement, bank account opening, professional engagement, and regulatory steps, so business expenses remained deductible even without revenue. The Tribunal therefore upheld deletion of both the section 68 addition and the disallowance of administrative expenditure and dismissed the Revenue's appeal.
Notional partners' capital entries credited as receivable under an LLP agreement were held outside section 68 because there was no actual inflow of funds during the year, the entries were only book adjustments, and the partners' identities and creditworthiness were not materially disputed; the addition was deleted. Administrative expenditure was also allowed because the LLP had already been set up through execution of the agreement, bank account opening, professional engagement, and regulatory steps, so business expenses remained deductible even without revenue. The Tribunal therefore upheld deletion of both the section 68 addition and the disallowance of administrative expenditure and dismissed the Revenue's appeal.
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