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 partly allowed the assessee's appeal. Travel expenses were partly disallowed by 30% considering personal element, while 70% were allowed as business expenses due to lack of documentary evidence establishing exclusive business purpose. Unexplained cash credits u/s 68 were confirmed as the assessee failed to prove identity, creditworthiness, and genuineness of transactions. Disallowance u/s 36(1)(va) for delayed PF/ESIC contributions was upheld following jurisdictional High Court's decision. However, disallowance u/s 36(1)(iii) for interest was deleted as the assessee demonstrated availability of sufficient interest-free funds.
The ITAT partly allowed the assessee's appeal. Travel expenses were partly disallowed by 30% considering personal element, while 70% were allowed as business expenses due to lack of documentary evidence establishing exclusive business purpose. Unexplained cash credits u/s 68 were confirmed as the assessee failed to prove identity, creditworthiness, and genuineness of transactions. Disallowance u/s 36(1)(va) for delayed PF/ESIC contributions was upheld following jurisdictional High Court's decision. However, disallowance u/s 36(1)(iii) for interest was deleted as the assessee demonstrated availability of sufficient interest-free funds.
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