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...
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Section 69A addition for unexplained income treated as advances was rightly deleted as the loan amounts were recorded in books, supported by bank statements and confirmations, even if details of immovable property transaction were unavailable. The assessee was not the owner of unrecorded assets, satisfying Section 69A conditions. CIT(A) rightly deleted the addition after considering all aspects. Addition of Rs. 1.70 crores relating to Outstripe Suppliers Pvt. Ltd. transaction was part of Rs. 2 crores addition for the same transaction in the previous year, leading to double addition, hence rightly deleted by CIT(A).
Section 69A addition for unexplained income treated as advances was rightly deleted as the loan amounts were recorded in books, supported by bank statements and confirmations, even if details of immovable property transaction were unavailable. The assessee was not the owner of unrecorded assets, satisfying Section 69A conditions. CIT(A) rightly deleted the addition after considering all aspects. Addition of Rs. 1.70 crores relating to Outstripe Suppliers Pvt. Ltd. transaction was part of Rs. 2 crores addition for the same transaction in the previous year, leading to double addition, hence rightly deleted by CIT(A).
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