Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
The ITAT Delhi, in an assessment u/s 153A, addressed the addition u/s 68 concerning income from undisclosed sources. The appellant, a partner in M/s. RNB Leasing and Financial Services, had filed a return for the assessment year. Following search and seizure operations, a key to an Indian Overseas Bank locker was found in the names of Lalita Bajaj and the appellant. Despite no incriminating evidence found during the search of the locker, the AO made additions u/s 68 in a similar case involving share allotment. However, in the present case, the appellant did not receive share application money or premium but was involved in the sale of investments/shares to other entities. The Department did not dispute the investment in shares during the earlier period. The ITAT allowed the appellant's grounds on merits, distinguishing the case from previous rulings.
The ITAT Delhi, in an assessment u/s 153A, addressed the addition u/s 68 concerning income from undisclosed sources. The appellant, a partner in M/s. RNB Leasing and Financial Services, had filed a return for the assessment year. Following search and seizure operations, a key to an Indian Overseas Bank locker was found in the names of Lalita Bajaj and the appellant. Despite no incriminating evidence found during the search of the locker, the AO made additions u/s 68 in a similar case involving share allotment. However, in the present case, the appellant did not receive share application money or premium but was involved in the sale of investments/shares to other entities. The Department did not dispute the investment in shares during the earlier period. The ITAT allowed the appellant's grounds on merits, distinguishing the case from previous rulings.
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