Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Cash withdrawals from ICICI and SBI bank accounts were treated as the source for deposits made during demonetization, as evidence showed the withdrawn funds were not used for other purposes. The burden of disproving availability of withdrawn cash for deposits lies with the Department. However, the claim of deposits originating from USD conversion was rejected due to lack of forex receipts and documentation from authorized money exchangers. As a result, an addition of Rs. 3,70,000/- was sustained u/s 69A for unexplained income. The penalty u/s 271AAC and interest u/ss 234A, 234B, and 234C will be recomputed based on the revised assessed income by the Assessing Officer. The Appellate Tribunal's decision was based on judicial precedents and evidentiary requirements for regulated foreign exchange transactions.
Cash withdrawals from ICICI and SBI bank accounts were treated as the source for deposits made during demonetization, as evidence showed the withdrawn funds were not used for other purposes. The burden of disproving availability of withdrawn cash for deposits lies with the Department. However, the claim of deposits originating from USD conversion was rejected due to lack of forex receipts and documentation from authorized money exchangers. As a result, an addition of Rs. 3,70,000/- was sustained u/s 69A for unexplained income. The penalty u/s 271AAC and interest u/ss 234A, 234B, and 234C will be recomputed based on the revised assessed income by the Assessing Officer. The Appellate Tribunal's decision was based on judicial precedents and evidentiary requirements for regulated foreign exchange transactions.
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