Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Unexplained credit claims for a spousal gift were not accepted on the record because the assessee failed to produce contemporaneous bank statements or a clear mode of transfer and material discrepancies existed in the donor's tax schedules; the AO lacked effective opportunity to verify late-disclosed details. Applying the prima facie onus for unexplained credits, the Tribunal remitted the matter to the jurisdictional AO for fresh adjudication and directed the assessee to furnish complete documentary evidence and permitted factual verification before any addition is made.
Unexplained credit claims for a spousal gift were not accepted on the record because the assessee failed to produce contemporaneous bank statements or a clear mode of transfer and material discrepancies existed in the donor's tax schedules; the AO lacked effective opportunity to verify late-disclosed details. Applying the prima facie onus for unexplained credits, the Tribunal remitted the matter to the jurisdictional AO for fresh adjudication and directed the assessee to furnish complete documentary evidence and permitted factual verification before any addition is made.
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