Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
Unexplained expenditure u/s 69C - genuineness of purchases - Assessee statedly had made purchases from the three parties - Payments made through banking channels - Assessee in our view has discharged his onus in respect of the subject purchases. AO has also not doubted the sales arising out of the said export activity and its GPR. This is not a case which falls within the ambit of Section 69C as held by the AO. - HC
Unexplained expenditure u/s 69C - genuineness of purchases - Assessee statedly had made purchases from the three parties - Payments made through banking channels - Assessee in our view has discharged his onus in respect of the subject purchases. AO has also not doubted the sales arising out of the said export activity and its GPR. This is not a case which falls within the ambit of Section 69C as held by the AO. - HC
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