Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Documentary evidence of a newly inducted partner's capital contribution through banking instruments can discharge the assessee's onus for cash-credit purposes. Where pay-in slips, the partner's capital account and the balance sheet establish that the credit represents partner capital, the absence of a partner confirmation alone does not establish that the explanation is false. Relying on the principle in Pankaj Dyestuff Industries, the High Court treated the unexplained-cash-credit addition as perverse and deleted it, allowing the tax appeal.
Documentary evidence of a newly inducted partner's capital contribution through banking instruments can discharge the assessee's onus for cash-credit purposes. Where pay-in slips, the partner's capital account and the balance sheet establish that the credit represents partner capital, the absence of a partner confirmation alone does not establish that the explanation is false. Relying on the principle in Pankaj Dyestuff Industries, the High Court treated the unexplained-cash-credit addition as perverse and deleted it, allowing the tax appeal.
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