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...
CBDT Instruction No. 1916, though framed for non-seizure of jewellery during search, was treated as a relevant guideline recognising customary family holdings of jewellery. The Tribunal accepted that jewellery within the prescribed limits could not be regarded as unexplained investment merely because it was found during search, especially where the assessee furnished explanations supported by family holdings, a wealth-tax disclosure for the HUF, purchase bills, and statements recorded during search and assessment. On that basis, the addition under unexplained investment was directed to be deleted to the extent covered by the instruction.
CBDT Instruction No. 1916, though framed for non-seizure of jewellery during search, was treated as a relevant guideline recognising customary family holdings of jewellery. The Tribunal accepted that jewellery within the prescribed limits could not be regarded as unexplained investment merely because it was found during search, especially where the assessee furnished explanations supported by family holdings, a wealth-tax disclosure for the HUF, purchase bills, and statements recorded during search and assessment. On that basis, the addition under unexplained investment was directed to be deleted to the extent covered by the instruction.
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