Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Assessment u/s 153A - completed assessment - As regards the stand of the respondent/revenue, that the appellant/assessee had refused to sign the consent form, Appellant submits that the consent form was framed in such a manner that if the appellant/assessee were to sign the form, he would end up incriminating himself even when position taken by him was that he did not maintain a bank account with the Geneva branch of HSBC Bank. - In view of the submission of the assessee and in the absence of incriminating material, the HC decided the question of law in favor of assessee and deleted the additions.
Assessment u/s 153A - completed assessment - As regards the stand of the respondent/revenue, that the appellant/assessee had refused to sign the consent form, Appellant submits that the consent form was framed in such a manner that if the appellant/assessee were to sign the form, he would end up incriminating himself even when position taken by him was that he did not maintain a bank account with the Geneva branch of HSBC Bank. - In view of the submission of the assessee and in the absence of incriminating material, the HC decided the question of law in favor of assessee and deleted the additions.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
Join Channel
TaxTMI 
