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...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Addition of bogus sales - difference in opinion between learned Members constituting the bench - The appellate tribunal (Third Member) addressed the dispute arising from alleged bogus sales transactions during the demonetization period. The Assessing Officer treated these transactions as unexplained cash credit under Section 68 of the Income Tax Act. However, the Tribunal found that the assessee sufficiently proved the authenticity of the sales through meticulous record-keeping and documentary evidence, despite challenges such as non-responses from some parties and allegations of sham transactions. - The Third Member upheld the decision of the learned Accountant Member to reject the addition under Section 68, considering the adequacy of evidence presented by the assessee.
Addition of bogus sales - difference in opinion between learned Members constituting the bench - The appellate tribunal (Third Member) addressed the dispute arising from alleged bogus sales transactions during the demonetization period. The Assessing Officer treated these transactions as unexplained cash credit under Section 68 of the Income Tax Act. However, the Tribunal found that the assessee sufficiently proved the authenticity of the sales through meticulous record-keeping and documentary evidence, despite challenges such as non-responses from some parties and allegations of sham transactions. - The Third Member upheld the decision of the learned Accountant Member to reject the addition under Section 68, considering the adequacy of evidence presented by the assessee.
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