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...
Addition u/s 68 - unexplained share application money - The Tribunal noted that the assessee provided complete details of the share subscribers, their financial capacity, and the transactions were carried out through banking channels, shifting the burden of proof to the Assessing Officer (AO) who failed to conduct an adequate inquiry to disprove the assessee's claims. Therefore, the primary onus placed on the assessee by section 68 was discharged, and the addition made by the AO was not justified.
Addition u/s 68 - unexplained share application money - The Tribunal noted that the assessee provided complete details of the share subscribers, their financial capacity, and the transactions were carried out through banking channels, shifting the burden of proof to the Assessing Officer (AO) who failed to conduct an adequate inquiry to disprove the assessee's claims. Therefore, the primary onus placed on the assessee by section 68 was discharged, and the addition made by the AO was not justified.
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