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...
Additions for alleged unexplained chit subscriptions require year-specific corroborative evidence; an annual average derived from aggregate chit dealings and an uncorroborated statement cannot establish fresh investment in the relevant year. Loose sheets showing unpaid instalments and loan liabilities do not prove undisclosed income where bid amounts were repayable through later instalments. Likewise, unexplained interest expenditure requires evidence of actual payment in the relevant year; an estimate based on averaged aggregate figures is insufficient, particularly where interest was deducted upfront from borrowings. The ITAT sustained deletion of additions under sections 69 and 69C and dismissed the Revenue's appeals.
Additions for alleged unexplained chit subscriptions require year-specific corroborative evidence; an annual average derived from aggregate chit dealings and an uncorroborated statement cannot establish fresh investment in the relevant year. Loose sheets showing unpaid instalments and loan liabilities do not prove undisclosed income where bid amounts were repayable through later instalments. Likewise, unexplained interest expenditure requires evidence of actual payment in the relevant year; an estimate based on averaged aggregate figures is insufficient, particularly where interest was deducted upfront from borrowings. The ITAT sustained deletion of additions under sections 69 and 69C and dismissed the Revenue's appeals.
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