Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
Undisclosed foreign investments in Dubai and Singapore were held unsubstantiated because the assessee failed to produce confirmations or reliable proof of the named lenders and source of funds; therefore the CIT(A)'s acceptance of disclosure was reversed. The tribunal reasoned that book entries alone did not establish the nature or origin of the investments and directed the assessing officer to require confirmations from the two foreign entities and satisfy himself on source and nature of funds. The tribunal also held that compounding of foreign exchange offences does not relieve the assessee from incometax or Black Money Act consequences, and remanded the matter for fresh inquiry.
Undisclosed foreign investments in Dubai and Singapore were held unsubstantiated because the assessee failed to produce confirmations or reliable proof of the named lenders and source of funds; therefore the CIT(A)'s acceptance of disclosure was reversed. The tribunal reasoned that book entries alone did not establish the nature or origin of the investments and directed the assessing officer to require confirmations from the two foreign entities and satisfy himself on source and nature of funds. The tribunal also held that compounding of foreign exchange offences does not relieve the assessee from incometax or Black Money Act consequences, and remanded the matter for fresh inquiry.
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