Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
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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