Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
The ITAT Mumbai held that addition as unexplained income based on accommodation entries lacked proof of transaction nature, creditworthiness, and genuineness. AO's premise that all entries were accommodation entries without examining their legitimacy was unfounded. Lack of evidence showing purchases or sales as bogus, or loans as unexplained, led to deletion of the addition. The Tribunal ruled in favor of the assessee, highlighting the importance of substantiating transactions to avoid unexplained income allegations.
The ITAT Mumbai held that addition as unexplained income based on accommodation entries lacked proof of transaction nature, creditworthiness, and genuineness. AO's premise that all entries were accommodation entries without examining their legitimacy was unfounded. Lack of evidence showing purchases or sales as bogus, or loans as unexplained, led to deletion of the addition. The Tribunal ruled in favor of the assessee, highlighting the importance of substantiating transactions to avoid unexplained income allegations.
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