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 High Court considered the treatment of unsecured loans disallowed in tax assessment at 9% p.a. The ITAT, u/s CIT-Appeals, held that the Respondent explained the transactions satisfactorily. Referring to another ITAT decision, it found the addition to income was based on conjecture. The HC concluded that no substantial legal question was raised for appeal as the evidence supported the Respondent's position. This case did not involve accounting entries disguising transactions, and factual aspects were resolved in favor of the Respondent.
The High Court considered the treatment of unsecured loans disallowed in tax assessment at 9% p.a. The ITAT, u/s CIT-Appeals, held that the Respondent explained the transactions satisfactorily. Referring to another ITAT decision, it found the addition to income was based on conjecture. The HC concluded that no substantial legal question was raised for appeal as the evidence supported the Respondent's position. This case did not involve accounting entries disguising transactions, and factual aspects were resolved in favor of the Respondent.
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