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Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
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On addition under s.68 r.w.s. 115BBE for an unsecured loan, the tribunal held that the loan stood established as genuine on parity with an earlier decision involving identical facts and allegations, and therefore deleted the addition. On addition under s.69A r.w.s. 115BBE for cash-in-hand treated as unexplained, it held that the cash was duly recorded in the books of multiple group entities and the source was thus explained; the deletion by the first appellate authority was upheld and the Revenue's ground was dismissed. On disallowance under s.37(1), it held that the AO made a double addition despite the assessee's own disallowance in computation; the deletion was sustained. - ITAT
On addition under s.68 r.w.s. 115BBE for an unsecured loan, the tribunal held that the loan stood established as genuine on parity with an earlier decision involving identical facts and allegations, and therefore deleted the addition. On addition under s.69A r.w.s. 115BBE for cash-in-hand treated as unexplained, it held that the cash was duly recorded in the books of multiple group entities and the source was thus explained; the deletion by the first appellate authority was upheld and the Revenue's ground was dismissed. On disallowance under s.37(1), it held that the AO made a double addition despite the assessee's own disallowance in computation; the deletion was sustained. - ITAT
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