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...
The ITAT Delhi addressed an addition u/s 41(1) converted from u/s 68, focusing on whether there was actual receipt of money or just journal entries for account adjustments. The AR argued that the entries were for loan adjustments from a prior year. The tribunal found the CIT(A)'s conclusion erroneous as there was no actual receipt of money, only journal entries reflecting borrowed funds and liabilities transferred to M/s Vrinda Developers Pvt. Ltd. The tribunal held that the journal entry did not constitute unexplained cash credit u/s 68, as it was a book entry transfer without a real cash credit. Citing a similar case, the tribunal emphasized the need for actual flow of funds to trigger the explanation requirement. Additionally, the tribunal allowed the expenditure related to a project started in the relevant year, despite the invoice being raised in the previous year. The decision favored the assessee based on project-related expenditure evidence.
The ITAT Delhi addressed an addition u/s 41(1) converted from u/s 68, focusing on whether there was actual receipt of money or just journal entries for account adjustments. The AR argued that the entries were for loan adjustments from a prior year. The tribunal found the CIT(A)'s conclusion erroneous as there was no actual receipt of money, only journal entries reflecting borrowed funds and liabilities transferred to M/s Vrinda Developers Pvt. Ltd. The tribunal held that the journal entry did not constitute unexplained cash credit u/s 68, as it was a book entry transfer without a real cash credit. Citing a similar case, the tribunal emphasized the need for actual flow of funds to trigger the explanation requirement. Additionally, the tribunal allowed the expenditure related to a project started in the relevant year, despite the invoice being raised in the previous year. The decision favored the assessee based on project-related expenditure evidence.
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