Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
Equivalent value attachment under money laundering law upheld where received funds were treated as proceeds of crime and prior-acquired property could...
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Reliance on hypothecation statement to determine taxable income was upheld where the hypothecation statement recorded quantities and values, was certified as reflecting books of account, and showed substantial unexplained discrepancies with bank records; the AO's notional addition was justified because inflated stock declarations to secure higher bank credit constituted commercially immoral conduct and admissible material. On appellate review, the HC found the Tribunal's affirmation rested on proper appreciation of the record and was neither perverse nor unsupported by evidence, therefore appellate interference was unwarranted and the addition sustained.
Reliance on hypothecation statement to determine taxable income was upheld where the hypothecation statement recorded quantities and values, was certified as reflecting books of account, and showed substantial unexplained discrepancies with bank records; the AO's notional addition was justified because inflated stock declarations to secure higher bank credit constituted commercially immoral conduct and admissible material. On appellate review, the HC found the Tribunal's affirmation rested on proper appreciation of the record and was neither perverse nor unsupported by evidence, therefore appellate interference was unwarranted and the addition sustained.
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