Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
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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