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Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
ITAT dismissed Revenue's appeal regarding additions under Section 68 and brokerage expense disallowance. The Tribunal held that revaluation of assets by AOP (DD Associates) and subsequent credit to assessee's capital account did not trigger taxable income, as no actual transfer or sale occurred. The revaluation merely recognized present value in books without creating tax liability. The share adjustment from 46.50% to 5% was legitimate accounting entry, not a tax avoidance scheme. Regarding brokerage expenses, ITAT upheld CIT(A)'s deletion of disallowance since payments were made via cheque with TDS deduction and specific purpose was established. Both grounds decided in assessee's favor.
ITAT dismissed Revenue's appeal regarding additions under Section 68 and brokerage expense disallowance. The Tribunal held that revaluation of assets by AOP (DD Associates) and subsequent credit to assessee's capital account did not trigger taxable income, as no actual transfer or sale occurred. The revaluation merely recognized present value in books without creating tax liability. The share adjustment from 46.50% to 5% was legitimate accounting entry, not a tax avoidance scheme. Regarding brokerage expenses, ITAT upheld CIT(A)'s deletion of disallowance since payments were made via cheque with TDS deduction and specific purpose was established. Both grounds decided in assessee's favor.
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