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...
Revisional jurisdiction under section 264 is benevolent and cannot be used to place an assessee in a worse position; the ITAT held that, while giving effect to the revision, the AO could not reopen matters already accepted and enhance the addition. On facts, the assessee's only income was salary received in cash, that source was undisputed, and the explanation that the balance demonetisation cash deposits came from past salary savings was treated as reasonable despite the absence of further documentation. The addition for unexplained cash deposits was deleted, and the connected duplicate appeal was dismissed.
Revisional jurisdiction under section 264 is benevolent and cannot be used to place an assessee in a worse position; the ITAT held that, while giving effect to the revision, the AO could not reopen matters already accepted and enhance the addition. On facts, the assessee's only income was salary received in cash, that source was undisputed, and the explanation that the balance demonetisation cash deposits came from past salary savings was treated as reasonable despite the absence of further documentation. The addition for unexplained cash deposits was deleted, and the connected duplicate appeal was dismissed.
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