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 - accommodation entries receipts - onus to prove - The tribunal held that, when an assessee provides all necessary documents and no adverse findings are noted, the assessee has discharged their onus. The tribunal referenced several case laws supporting this principle, including the principle that the source of the source of investment is not required to be explained. The addition for commission was also deleted as the main addition u/s 68 was removed.
Addition u/s 68 - accommodation entries receipts - onus to prove - The tribunal held that, when an assessee provides all necessary documents and no adverse findings are noted, the assessee has discharged their onus. The tribunal referenced several case laws supporting this principle, including the principle that the source of the source of investment is not required to be explained. The addition for commission was also deleted as the main addition u/s 68 was removed.
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