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 on the basis of declaration made by assessee during a search action u/s 132 - The ITAT found no merit in the revenue's arguments, noting that the addition was based solely on the assessee's statement during the search. The ITAT emphasized that under the scheme of Income-tax, only the correct income should be taxed, and the CBDT instruction dated 10.03.2003 restricts making additions based on mere confessions during search/survey without corroborative evidence. The ITAT concluded that the addition made by the revenue authorities was not justified and ordered its deletion.
Addition on the basis of declaration made by assessee during a search action u/s 132 - The ITAT found no merit in the revenue's arguments, noting that the addition was based solely on the assessee's statement during the search. The ITAT emphasized that under the scheme of Income-tax, only the correct income should be taxed, and the CBDT instruction dated 10.03.2003 restricts making additions based on mere confessions during search/survey without corroborative evidence. The ITAT concluded that the addition made by the revenue authorities was not justified and ordered its deletion.
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