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...
Recorded bank credits supported by books of account, confirmations, returns, ledgers and bank statements could not be treated as unexplained money under section 69A, because the assessee was not shown to be the owner of unrecorded money and the addition lacked corroborative evidence that the funds were undisclosed income. The deletion of the addition, including the cash deposit component, was upheld. Reassessment also failed because the recorded reasons rested on incorrect facts: the assessee was said to have three bank accounts and higher non-cash credits, but verification showed only one bank account and the alleged information was wrong. The section 148 notice and reassessment proceedings were therefore held unsustainable.
Recorded bank credits supported by books of account, confirmations, returns, ledgers and bank statements could not be treated as unexplained money under section 69A, because the assessee was not shown to be the owner of unrecorded money and the addition lacked corroborative evidence that the funds were undisclosed income. The deletion of the addition, including the cash deposit component, was upheld. Reassessment also failed because the recorded reasons rested on incorrect facts: the assessee was said to have three bank accounts and higher non-cash credits, but verification showed only one bank account and the alleged information was wrong. The section 148 notice and reassessment proceedings were therefore held unsustainable.
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