Regulatory consolidation for investment advisers: SEBI issues master circular consolidating guidance and prescribing compliance, reporting, fees and s...
Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Addition under s.69 for alleged unexplained investment by a non-resident in its Indian subsidiary was held unsustainable where the investment was recorded in the assessee's books and its nature and source were explained as equity funding received from its foreign parent and onward invested in India, supported by bank statements and audited accounts. Section 69 applies only to investments not recorded in the books and lacking satisfactory explanation; insisting on further source proof despite recorded entries was a misapplication of the provision. The matter was remitted only for limited verification of annual accounts evidencing the parent funding, with a direction to delete the addition if verified, and the appeal was allowed. - ITAT
Addition under s.69 for alleged unexplained investment by a non-resident in its Indian subsidiary was held unsustainable where the investment was recorded in the assessee's books and its nature and source were explained as equity funding received from its foreign parent and onward invested in India, supported by bank statements and audited accounts. Section 69 applies only to investments not recorded in the books and lacking satisfactory explanation; insisting on further source proof despite recorded entries was a misapplication of the provision. The matter was remitted only for limited verification of annual accounts evidencing the parent funding, with a direction to delete the addition if verified, and the appeal was allowed. - ITAT
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