Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
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Addition u/s 69 - addition based on the estimation of the cost of acquisition of the property - The ITAT observed that the AO had relied heavily on statements obtained during the survey proceedings, particularly regarding the payment of on-money for the property purchase. However, the Tribunal emphasized that such statements, which were later retracted, could not constitute valid evidence for making additions to the appellant's income. Furthermore, the Tribunal noted that the AO had not provided any supporting material apart from these statements to justify the addition. Considering these factors, the Tribunal held that the AO's decision to estimate the property acquisition cost at a higher value lacked sufficient basis and was not supported by credible evidence.
Addition u/s 69 - addition based on the estimation of the cost of acquisition of the property - The ITAT observed that the AO had relied heavily on statements obtained during the survey proceedings, particularly regarding the payment of on-money for the property purchase. However, the Tribunal emphasized that such statements, which were later retracted, could not constitute valid evidence for making additions to the appellant's income. Furthermore, the Tribunal noted that the AO had not provided any supporting material apart from these statements to justify the addition. Considering these factors, the Tribunal held that the AO's decision to estimate the property acquisition cost at a higher value lacked sufficient basis and was not supported by credible evidence.
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