Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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Reopening was upheld since approval u/s 151 validly relied on recorded "reasons to believe" founded on specific third-party RTGS information indicating alleged bogus purchases/expenses; hence reassessment proceedings were not vitiated. Addition u/s 69 was deleted because s.69 applies only where unrecorded "investments" are found, and alleged bogus purchases recorded in the books do not constitute unrecorded investments; absent any stock/inventory discrepancy or rejection of books, and with no allegation that purchase funding was outside known book sources, the assessee's onus to explain nature and source stood satisfied. Appeal allowed. - ITAT
Reopening was upheld since approval u/s 151 validly relied on recorded "reasons to believe" founded on specific third-party RTGS information indicating alleged bogus purchases/expenses; hence reassessment proceedings were not vitiated. Addition u/s 69 was deleted because s.69 applies only where unrecorded "investments" are found, and alleged bogus purchases recorded in the books do not constitute unrecorded investments; absent any stock/inventory discrepancy or rejection of books, and with no allegation that purchase funding was outside known book sources, the assessee's onus to explain nature and source stood satisfied. Appeal allowed. - ITAT
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