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 - the Tribunal noted the extensive documentary evidence provided by the assessee to establish the legitimacy of the loan transactions. However, the AO failed to conduct proper investigations and relied solely on the report from the investigation wing. As the assessee had fulfilled its initial burden of proof, the Tribunal directed the deletion of the addition.
Addition u/s 68 - the Tribunal noted the extensive documentary evidence provided by the assessee to establish the legitimacy of the loan transactions. However, the AO failed to conduct proper investigations and relied solely on the report from the investigation wing. As the assessee had fulfilled its initial burden of proof, the Tribunal directed the deletion of the addition.
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