Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
Additions founded on uncorroborated seized loose papers and undated marketing 'welcome' letters, and extrapolation of alleged sales using portal rates, are unsustainable where no receipts, bank trail, agreements or buyer admissions exist; such additions were deleted. Reliance on a DVO valuation to estimate unaccounted construction expenditure was held arbitrary where payments appeared in books with bank credits and TDS and no independent enquiry supported out of books spending; that addition was deleted. Higher gross profit in jewellery was not treated as unexplained credit where audited books, stock records and verifiable purchases supported receipts. Unsecured loans supported by bank evidence, confirmations and repayments were not taxable as unexplained credit. Approval under section 153D was found valid.
Additions founded on uncorroborated seized loose papers and undated marketing 'welcome' letters, and extrapolation of alleged sales using portal rates, are unsustainable where no receipts, bank trail, agreements or buyer admissions exist; such additions were deleted. Reliance on a DVO valuation to estimate unaccounted construction expenditure was held arbitrary where payments appeared in books with bank credits and TDS and no independent enquiry supported out of books spending; that addition was deleted. Higher gross profit in jewellery was not treated as unexplained credit where audited books, stock records and verifiable purchases supported receipts. Unsecured loans supported by bank evidence, confirmations and repayments were not taxable as unexplained credit. Approval under section 153D was found valid.
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