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...
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Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Addition u/s 68 - We do not understand proposition of the assessee that cash had changed the hands from the company to its promoter–Director without any reason and there is no reason forthcoming as to why the cash was paid in cash by the three parties. There is no document produced before either the AO or before CIT (Appeals) or before us to prove the genuineness of the transaction. - While deleting the addition the CIT (Appeals) has not discussed about the proving of genuineness of the transaction by the assessee. - Matter restored back - AT
Addition u/s 68 - We do not understand proposition of the assessee that cash had changed the hands from the company to its promoter–Director without any reason and there is no reason forthcoming as to why the cash was paid in cash by the three parties. There is no document produced before either the AO or before CIT (Appeals) or before us to prove the genuineness of the transaction. - While deleting the addition the CIT (Appeals) has not discussed about the proving of genuineness of the transaction by the assessee. - Matter restored back - AT
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