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...
Reopening assessment u/s 148 upheld based on specific information from DDIT (Inv) about transactions with M/s Vishnu Trading Co, providing reasonable belief of escaped income. Addition u/s 68 as unexplained cash credits deleted as books not rejected, quantitative details provided, and lack of evidence of accommodation entries. Cross-examination opportunity denied, violating natural justice principles. Transactions with M/s Edelweiss Commodities misunderstood. Consequential deletion of taxation u/s 115BBE, interest u/ss 234A, 234B, 234C, 234D, and penalty u/s 271(1)(c).
Reopening assessment u/s 148 upheld based on specific information from DDIT (Inv) about transactions with M/s Vishnu Trading Co, providing reasonable belief of escaped income. Addition u/s 68 as unexplained cash credits deleted as books not rejected, quantitative details provided, and lack of evidence of accommodation entries. Cross-examination opportunity denied, violating natural justice principles. Transactions with M/s Edelweiss Commodities misunderstood. Consequential deletion of taxation u/s 115BBE, interest u/ss 234A, 234B, 234C, 234D, and penalty u/s 271(1)(c).
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