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 u/s 69A - cash loans given by the assessee as unexplained - decoding of the entries in the seized materials - The tribunal found that the assessing officer's reliance on statements recorded during the search was insufficient to justify the addition under section 69A. They emphasized that the assessing officer did not entertain the appellant's request for cross-examination, and the retracted statements raised doubts about their reliability. Additionally, the tribunal noted discrepancies in the interpretation of entries and the lack of concrete evidence connecting the appellant to the transactions. Therefore, they deemed the addition unjustified and deleted it.
Addition u/s 69A - cash loans given by the assessee as unexplained - decoding of the entries in the seized materials - The tribunal found that the assessing officer's reliance on statements recorded during the search was insufficient to justify the addition under section 69A. They emphasized that the assessing officer did not entertain the appellant's request for cross-examination, and the retracted statements raised doubts about their reliability. Additionally, the tribunal noted discrepancies in the interpretation of entries and the lack of concrete evidence connecting the appellant to the transactions. Therefore, they deemed the addition unjustified and deleted it.
Note: It is a system-generated summary and is for quick reference only.