Political contribution deductions require assessee-specific proof before cash-back allegations can justify disallowance or unexplained-money additions...
TP Adjustment - selection of MAM [Most Appropriate Method] - The High Court upheld the Tribunal's decision, affirming TNMM as the appropriate method for benchmarking transactions. It criticized the TPO's one-to-one comparison and affirmed Assessee's use of TNMM. The High Court found fault with the TPO's reliance on the Bloomberg database without adequate clarification or consideration of Assessee's objections. It supported Assessee's contention regarding the reliability of Indian Customs data.
TP Adjustment - selection of MAM [Most Appropriate Method] - The High Court upheld the Tribunal's decision, affirming TNMM as the appropriate method for benchmarking transactions. It criticized the TPO's one-to-one comparison and affirmed Assessee's use of TNMM. The High Court found fault with the TPO's reliance on the Bloomberg database without adequate clarification or consideration of Assessee's objections. It supported Assessee's contention regarding the reliability of Indian Customs data.
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