Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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Unexplained jewellery could not be added where the assessee produced a detailed break-up of ornaments, family-wise allocation, affidavits for gifts on marriage and other occasions, supporting bills, and bank withdrawals showing purchases. CBDT Instruction No. 1916 and the precedent in Vibhu Aggarwal were applied to recognise reasonable family holding of jewellery having regard to status, customs, and customary occasions, so the Assessing Officer's addition was deleted.
Unexplained jewellery could not be added where the assessee produced a detailed break-up of ornaments, family-wise allocation, affidavits for gifts on marriage and other occasions, supporting bills, and bank withdrawals showing purchases. CBDT Instruction No. 1916 and the precedent in Vibhu Aggarwal were applied to recognise reasonable family holding of jewellery having regard to status, customs, and customary occasions, so the Assessing Officer's addition was deleted.
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