Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
Section 69C concerns whether the source of expenditure remains unexplained, not merely whether underlying purchases are alleged to be bogus. Documentary support for transactions and bank disbursements upon encashment of letters of credit may explain the funding source. Allegations that goods did not move or documents were forged require independent inquiry, verification, examination of beneficiary entities, or other cogent material. Where sales are accepted, an addition made under section 69C cannot be sustained by recasting it under a different provision. The discussion also addresses consequential taxation under section 115BBE.
Section 69C concerns whether the source of expenditure remains unexplained, not merely whether underlying purchases are alleged to be bogus. Documentary support for transactions and bank disbursements upon encashment of letters of credit may explain the funding source. Allegations that goods did not move or documents were forged require independent inquiry, verification, examination of beneficiary entities, or other cogent material. Where sales are accepted, an addition made under section 69C cannot be sustained by recasting it under a different provision. The discussion also addresses consequential taxation under section 115BBE.
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