Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
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The ITAT upheld the addition under Section 68 of the Income Tax Act regarding unsecured loans and share capital. Despite the Assessee's claims of secured loans from banks and share applicant companies' replies, the Tribunal found insufficient evidence to substantiate the genuineness of transactions. The share applicant companies' stereotypical responses and failure to appear before the Assessing Officer, coupled with the Assessee's inability to discharge the burden of proof under Section 68, led to the confirmation of the original addition. The Tribunal dismissed the Assessee's appeal, finding no merit in the grounds presented.
The ITAT upheld the addition under Section 68 of the Income Tax Act regarding unsecured loans and share capital. Despite the Assessee's claims of secured loans from banks and share applicant companies' replies, the Tribunal found insufficient evidence to substantiate the genuineness of transactions. The share applicant companies' stereotypical responses and failure to appear before the Assessing Officer, coupled with the Assessee's inability to discharge the burden of proof under Section 68, led to the confirmation of the original addition. The Tribunal dismissed the Assessee's appeal, finding no merit in the grounds presented.
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