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...
Addition u/s 68 - none of the lenders is alleged to be an entry provider. A perusal of their bank statements reveals that they have given loan to the assessee out of their available balances and it is not the case of the Revenue that prior to issuing cheques, there is a deposit of cash in the lender’s bank account. Therefore, it can be safely concluded that the assessee has not purchased cheque by paying cash. - CIT(A) rightly deleted the additions - AT
Addition u/s 68 - none of the lenders is alleged to be an entry provider. A perusal of their bank statements reveals that they have given loan to the assessee out of their available balances and it is not the case of the Revenue that prior to issuing cheques, there is a deposit of cash in the lender’s bank account. Therefore, it can be safely concluded that the assessee has not purchased cheque by paying cash. - CIT(A) rightly deleted the additions - AT
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