Working capital adjustment, comparable selection and trade receivables interest were revisited in transfer pricing, with key additions deleted and rem...
Assessee challenged addition on account of unproved sundry creditors u/s 41(1), contending evidence of liability cessation was provided. AO held assessee failed to prove identity, creditworthiness, and genuineness despite opportunities. However, assessee filed relevant details of sundry credits with opening balances and settlements in relevant year. Revenue's attempt to invoke section 68 lacked discussion on assessee's failure to discharge onus. ITAT concluded in these facts, whether u/s 41(1) or 68, AO could not make impugned addition on both counts. Addition rejected accordingly.
Assessee challenged addition on account of unproved sundry creditors u/s 41(1), contending evidence of liability cessation was provided. AO held assessee failed to prove identity, creditworthiness, and genuineness despite opportunities. However, assessee filed relevant details of sundry credits with opening balances and settlements in relevant year. Revenue's attempt to invoke section 68 lacked discussion on assessee's failure to discharge onus. ITAT concluded in these facts, whether u/s 41(1) or 68, AO could not make impugned addition on both counts. Addition rejected accordingly.
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