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...
The Tribunal held that the assessee's cash deposits during the demonetization period were from sale proceeds and collections from sundry debtors/trade debtors. The assessee maintained proper books of accounts subjected to tax audit, and the sales were reflected and offered to tax. Adding the same again would amount to impermissible double taxation. The assessee discharged the burden of proving the source of the cash deposited, and the authorities failed to rebut it. The Tribunal found no prohibition on dealing with Specified Bank Notes until December 31, 2016, under the Specified Bank Notes (Cessation of Liabilities) Act, 2017. Consequently, the assessee's appeal was allowed.
The Tribunal held that the assessee's cash deposits during the demonetization period were from sale proceeds and collections from sundry debtors/trade debtors. The assessee maintained proper books of accounts subjected to tax audit, and the sales were reflected and offered to tax. Adding the same again would amount to impermissible double taxation. The assessee discharged the burden of proving the source of the cash deposited, and the authorities failed to rebut it. The Tribunal found no prohibition on dealing with Specified Bank Notes until December 31, 2016, under the Specified Bank Notes (Cessation of Liabilities) Act, 2017. Consequently, the assessee's appeal was allowed.
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