Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
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Bogus commodity loss transaction identified as mere accommodation entry facilitated through complex fund routing. Revenue's investigation revealed modus operandi of transactions between parties, corroborated by money trail and admission by directors, establishing impugned transactions as accommodation entries for tax benefit. Burden of proof shifted to assessee to controvert findings, which was not discharged satisfactorily. Transaction treated as bogus, reducing cost of land acquisition. Unexplained credit addition deleted as source of funds established as genuine. Interest disallowance on loans reversed as source held genuine. Disallowance u/s 14A rightly deleted in absence of exempt income. Appellate Tribunal upheld Revenue's findings and assessee's contentions rejected.
Bogus commodity loss transaction identified as mere accommodation entry facilitated through complex fund routing. Revenue's investigation revealed modus operandi of transactions between parties, corroborated by money trail and admission by directors, establishing impugned transactions as accommodation entries for tax benefit. Burden of proof shifted to assessee to controvert findings, which was not discharged satisfactorily. Transaction treated as bogus, reducing cost of land acquisition. Unexplained credit addition deleted as source of funds established as genuine. Interest disallowance on loans reversed as source held genuine. Disallowance u/s 14A rightly deleted in absence of exempt income. Appellate Tribunal upheld Revenue's findings and assessee's contentions rejected.
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