Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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The ITAT held that additions based on loose papers/documents found during search at the assessee's premises without further corroboration would be contrary to judicial precedents. The circumstantial evidence did not contradict the assessee's assertions. Despite the search, no irregularities like excess cash or unaccounted assets were discovered. The adverse view by the AO and CIT(A) based solely on the loose papers appeared abstract without substantiation. The onus to prove the allegations lies with the Revenue, and the assessee cannot be burdened to prove a negative. Absence of supporting material, the assessee's denial, and their social status raised doubts favoring the assessee.
The ITAT held that additions based on loose papers/documents found during search at the assessee's premises without further corroboration would be contrary to judicial precedents. The circumstantial evidence did not contradict the assessee's assertions. Despite the search, no irregularities like excess cash or unaccounted assets were discovered. The adverse view by the AO and CIT(A) based solely on the loose papers appeared abstract without substantiation. The onus to prove the allegations lies with the Revenue, and the assessee cannot be burdened to prove a negative. Absence of supporting material, the assessee's denial, and their social status raised doubts favoring the assessee.
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