Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
In a section 68 dispute over an unexplained unsecured loan, the High Court noted that the Tribunal had relied on the undisputed repayment of the loan through banking channels and its disclosure in the books. It accepted the Tribunal's view, supported by jurisdictional precedents, that such repayment and disclosure were sufficient to negate the addition in the absence of further material showing an accommodation entry. The Court found no error in deleting the addition, held that no substantial question of law arose, and dismissed the Revenue's appeals.
In a section 68 dispute over an unexplained unsecured loan, the High Court noted that the Tribunal had relied on the undisputed repayment of the loan through banking channels and its disclosure in the books. It accepted the Tribunal's view, supported by jurisdictional precedents, that such repayment and disclosure were sufficient to negate the addition in the absence of further material showing an accommodation entry. The Court found no error in deleting the addition, held that no substantial question of law arose, and dismissed the Revenue's appeals.
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