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...
The ITAT Delhi held that the addition for unexplained investment made to a company was unjustified. The Tribunal found that the total investments were made through a banking channel, specifically after withdrawals from an Axis Bank Account. The source of deposits in the account was explained and admitted, making the addition on account of withdrawals irrational. The addition from an undisclosed source related to a bridal business was based on suspicion, with the AO and CIT(A) erroneously holding 30% of deposits. The Tribunal considered the nature of the business and calculated the security amount at 10% of the hire charges. The assessee satisfactorily explained the bank entries, leading to the appeal being allowed due to a miscarriage of justice.
The ITAT Delhi held that the addition for unexplained investment made to a company was unjustified. The Tribunal found that the total investments were made through a banking channel, specifically after withdrawals from an Axis Bank Account. The source of deposits in the account was explained and admitted, making the addition on account of withdrawals irrational. The addition from an undisclosed source related to a bridal business was based on suspicion, with the AO and CIT(A) erroneously holding 30% of deposits. The Tribunal considered the nature of the business and calculated the security amount at 10% of the hire charges. The assessee satisfactorily explained the bank entries, leading to the appeal being allowed due to a miscarriage of justice.
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