Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-part...
Mutual current-account transactions excluded from deemed dividend treatment where no fresh borrowing arose; unsupported unsecured-loan addition also f...
Where transfer pricing analysis was applied uniformly to all international transactions and no separate benchmarking was carried out for non-US based AE transactions, the Tribunal treated the BAPA margin as a reliable persuasive benchmark. It noted that the Revenue failed to show any material difference in the FAR profile of the non-US transactions from those covered by the BAPA. Applying the principle of consistency, the Tribunal accepted the assessee's claim and directed adoption of the BAPA margin for determining the arm's length price of the non-US based AE transactions as well. The appeals were allowed.
Where transfer pricing analysis was applied uniformly to all international transactions and no separate benchmarking was carried out for non-US based AE transactions, the Tribunal treated the BAPA margin as a reliable persuasive benchmark. It noted that the Revenue failed to show any material difference in the FAR profile of the non-US transactions from those covered by the BAPA. Applying the principle of consistency, the Tribunal accepted the assessee's claim and directed adoption of the BAPA margin for determining the arm's length price of the non-US based AE transactions as well. The appeals were allowed.
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