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...
Bogus STCL - Disallowance of Loss arising from the trading in shares - accommodation entry of STCL - the fact remains that the findings of the lower authorities are not based on evidence but on generalizations and probabilities. The AO could not place anything on record, maybe through a process of his own enquiry, to decisively prove that assessee has obtained bogus STCL through his connivance with entry operators / exit providers. - The claim of the assessee appears to have been rejected more on the basis of presumption rather than evidence. - Additions deleted - AT
Bogus STCL - Disallowance of Loss arising from the trading in shares - accommodation entry of STCL - the fact remains that the findings of the lower authorities are not based on evidence but on generalizations and probabilities. The AO could not place anything on record, maybe through a process of his own enquiry, to decisively prove that assessee has obtained bogus STCL through his connivance with entry operators / exit providers. - The claim of the assessee appears to have been rejected more on the basis of presumption rather than evidence. - Additions deleted - AT
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