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...
Reassessment based on Investigation Wing information may rest on tangible material where it specifically links alleged accommodation entries to the taxpayer's loan transaction, creating a live nexus and demonstrating independent application of mind rather than borrowed satisfaction. For an unsecured-loan credit, confirmation, PAN, tax return, audited financial statements, bank records, interest payments with tax deduction, and repayment can discharge the taxpayer's burden. Third-party investigation material alone does not displace this evidence without proof that the taxpayer paid cash for the loan or that the lender's funds belonged to the taxpayer. The reassessment was sustained, while the cash-credit addition was deleted.
Reassessment based on Investigation Wing information may rest on tangible material where it specifically links alleged accommodation entries to the taxpayer's loan transaction, creating a live nexus and demonstrating independent application of mind rather than borrowed satisfaction. For an unsecured-loan credit, confirmation, PAN, tax return, audited financial statements, bank records, interest payments with tax deduction, and repayment can discharge the taxpayer's burden. Third-party investigation material alone does not displace this evidence without proof that the taxpayer paid cash for the loan or that the lender's funds belonged to the taxpayer. The reassessment was sustained, while the cash-credit addition was deleted.
Note: It is a system-generated summary and is for quick reference only.
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