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...
Burden of proof for unexplained credits lies on the assessee in whose books the entries appear; the assessee must prove identity, creditworthiness and genuineness of creditors, failing which additions are sustainable. Evidence from search records and sworn statements established that the assessee functioned as a conduit for accommodation entries, so AO's additions treating credits as unexplained were restored. The CIT(A)'s view that protective additions fall because beneficiaries faced substantive additions was rejected; liability for unexplained credits attaches independently to the booked assessee, and consequential additions for parallel undisclosed cash routing were upheld.
Burden of proof for unexplained credits lies on the assessee in whose books the entries appear; the assessee must prove identity, creditworthiness and genuineness of creditors, failing which additions are sustainable. Evidence from search records and sworn statements established that the assessee functioned as a conduit for accommodation entries, so AO's additions treating credits as unexplained were restored. The CIT(A)'s view that protective additions fall because beneficiaries faced substantive additions was rejected; liability for unexplained credits attaches independently to the booked assessee, and consequential additions for parallel undisclosed cash routing were upheld.
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