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...
Section 2(11) of the Black Money Act treats a foreign asset as undisclosed where no explanation of its acquisition source is provided or the explanation is unsatisfactory. The text explains that foreign investments and bank assets sourced from gifts received during Belgian residency were supported by documents, banking records, donor statements and subsequent verification. As no material linked the assets to Indian taxable income, undisclosed business activity, accommodation arrangements or transfers of untaxed Indian funds, suspicion could not replace evidence. The foreign-asset addition was deleted, and the consequential penalty was also deleted because its underlying addition did not survive.
Section 2(11) of the Black Money Act treats a foreign asset as undisclosed where no explanation of its acquisition source is provided or the explanation is unsatisfactory. The text explains that foreign investments and bank assets sourced from gifts received during Belgian residency were supported by documents, banking records, donor statements and subsequent verification. As no material linked the assets to Indian taxable income, undisclosed business activity, accommodation arrangements or transfers of untaxed Indian funds, suspicion could not replace evidence. The foreign-asset addition was deleted, and the consequential penalty was also deleted because its underlying addition did not survive.
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