Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
The ITAT held that once the source of cash is taxed, it cannot be further taxed as unexplained cash expenditure in the hands of the assessee company. The assessee had furnished details regarding the source of cash expenditures which were accepted by the Interim Board for Settlement. The addition made u/s 69C for cash payments treated as unexplained expenditure by the Assessing Officer was deleted, as it would amount to double taxation, since the cash income was already offered to tax in the hands of the Director. The issue was decided in favour of the assessee.
The ITAT held that once the source of cash is taxed, it cannot be further taxed as unexplained cash expenditure in the hands of the assessee company. The assessee had furnished details regarding the source of cash expenditures which were accepted by the Interim Board for Settlement. The addition made u/s 69C for cash payments treated as unexplained expenditure by the Assessing Officer was deleted, as it would amount to double taxation, since the cash income was already offered to tax in the hands of the Director. The issue was decided in favour of the assessee.
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