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...
Jurisdiction under section 153C failed because the seized diaries and notebooks were recovered from a third person, did not name the assessee, and contained no identifying material conclusively linking the code "DD" to him. Corroboration from a contact saved as "DD Personal", Truecaller data and other digital material was held too tenuous to supply the missing nexus. Presumptions under sections 132(4A) and 292C were confined to the person from whom the documents were found and could not be transposed to the assessee without independent evidence. The notice, consequential assessment and addition were therefore unsustainable, and the Revenue's appeal was dismissed.
Jurisdiction under section 153C failed because the seized diaries and notebooks were recovered from a third person, did not name the assessee, and contained no identifying material conclusively linking the code "DD" to him. Corroboration from a contact saved as "DD Personal", Truecaller data and other digital material was held too tenuous to supply the missing nexus. Presumptions under sections 132(4A) and 292C were confined to the person from whom the documents were found and could not be transposed to the assessee without independent evidence. The notice, consequential assessment and addition were therefore unsustainable, and the Revenue's appeal was dismissed.
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