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...
HC held that additions to income under block assessment can be made based on statements recorded u/s 132(4) and seized materials. The appellant's argument attributing income to deceased father was rejected due to lack of supporting evidence. The court found the statement reliable as the appellant did not retract it and failed to respond to notice u/s 158BC. Seized materials and assessee's own statement substantiated the income additions. Relying on precedent, the court affirmed that where inferences about undisclosed income are strong and based on search materials and statements, such additions are permissible. The order was ultimately decided in favor of the revenue.
HC held that additions to income under block assessment can be made based on statements recorded u/s 132(4) and seized materials. The appellant's argument attributing income to deceased father was rejected due to lack of supporting evidence. The court found the statement reliable as the appellant did not retract it and failed to respond to notice u/s 158BC. Seized materials and assessee's own statement substantiated the income additions. Relying on precedent, the court affirmed that where inferences about undisclosed income are strong and based on search materials and statements, such additions are permissible. The order was ultimately decided in favor of the revenue.
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