International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
Interest claimed on unsecured loans admitted to be bogus accommodation entries is treated as non-deductible as a consequential matter. The tax deducted at source component of such interest must be excluded from the disallowance. Estimated commission additions for obtaining accommodation entries require corroborative evidence of payment or a reliable basis for estimation; a presumption alone is insufficient. Accordingly, the interest disallowance is retained after excluding tax deducted at source, while the commission additions are deleted.
Interest claimed on unsecured loans admitted to be bogus accommodation entries is treated as non-deductible as a consequential matter. The tax deducted at source component of such interest must be excluded from the disallowance. Estimated commission additions for obtaining accommodation entries require corroborative evidence of payment or a reliable basis for estimation; a presumption alone is insufficient. Accordingly, the interest disallowance is retained after excluding tax deducted at source, while the commission additions are deleted.
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