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...
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.
Note: It is a system-generated summary and is for quick reference only.