Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Revision u/s 263 - Addition u/s 68 r.w.s. 115BBE - no verification of ‘other income’ was done by Ld. AO. In fact during revisional proceedings, the assessee shifted the stand and submitted that it was surplus out of deposits and withdrawals which are contradictory to return of income. It is clear that the nature and source of Rs.7.55 Lacs was nowhere examined by Ld. AO as well as no explanation for the same was furnished by the assessee. Under such circumstances, the revision was justified. - AT
Revision u/s 263 - Addition u/s 68 r.w.s. 115BBE - no verification of ‘other income’ was done by Ld. AO. In fact during revisional proceedings, the assessee shifted the stand and submitted that it was surplus out of deposits and withdrawals which are contradictory to return of income. It is clear that the nature and source of Rs.7.55 Lacs was nowhere examined by Ld. AO as well as no explanation for the same was furnished by the assessee. Under such circumstances, the revision was justified. - AT
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