Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Addition of interest on interest free loans advanced by assessee Company to sister concerns/related parties disallowed. Onus on assessee to prove commercial expediency for advances taken interest free from related parties. Assessee failed to substantiate commercial expediency for interest free advance to related party M/s. Diehard Dies Pvt. Limited. CIT(A) erred in considering transaction arose out of business/commercial expediency. Order of CIT(A) set aside, restoring AO's order. Revenue's appeal allowed.
Addition of interest on interest free loans advanced by assessee Company to sister concerns/related parties disallowed. Onus on assessee to prove commercial expediency for advances taken interest free from related parties. Assessee failed to substantiate commercial expediency for interest free advance to related party M/s. Diehard Dies Pvt. Limited. CIT(A) erred in considering transaction arose out of business/commercial expediency. Order of CIT(A) set aside, restoring AO's order. Revenue's appeal allowed.
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