SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Addition u/s 68 - assessee has discharged the initial onus cast on it in terms of identity, creditworthiness and genuineness of the transaction - Genuineness accepted in investor company u/s 143(3) - no linkage which can be said to have been established by the Revenue between the assessee’s undisclosed income which is routed back in form of share capital - addition not sustainable.
Addition u/s 68 - assessee has discharged the initial onus cast on it in terms of identity, creditworthiness and genuineness of the transaction - Genuineness accepted in investor company u/s 143(3) - no linkage which can be said to have been established by the Revenue between the assessee’s undisclosed income which is routed back in form of share capital - addition not sustainable.
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