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...
ITAT upheld CIT(A)'s order, dismissing revenue's appeal regarding unexplained cash deposits under Section 68 and Section 115BBE. The tribunal found that the assessee substantiated the cash deposits through bank certificates and sales receipts from audited accounts. No contrary evidence was presented by the Assessing Officer challenging the source of deposits. Similarly, for disallowance under Section 40A(3), the tribunal confirmed CIT(A)'s deletion of addition due to lack of specific violation proof. The revenue's contentions were rejected, and the appeal was comprehensively dismissed.
ITAT upheld CIT(A)'s order, dismissing revenue's appeal regarding unexplained cash deposits under Section 68 and Section 115BBE. The tribunal found that the assessee substantiated the cash deposits through bank certificates and sales receipts from audited accounts. No contrary evidence was presented by the Assessing Officer challenging the source of deposits. Similarly, for disallowance under Section 40A(3), the tribunal confirmed CIT(A)'s deletion of addition due to lack of specific violation proof. The revenue's contentions were rejected, and the appeal was comprehensively dismissed.
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