Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Natural justice in insolvency-professional discipline requires disclosed material; notices based on extraneous material and ignored defences are vitia...
Professional fees paid for services linked to imports from OFAC-restricted Iranian-origin goods were held allowable under section 37(1) because the assessee proved the recipient's identity, genuineness of payment, and banking trail, while the payee confirmed the transactions and disclosed them in its tax records. The Tribunal accepted that the services addressed abnormal remittance delays caused by OFAC-related banking scrutiny, and that comparative material showed improved payment cycles, turnover, and profits after the services were used. Revenue's disallowance failed because it relied on suspicion without independent enquiry or evidence that the services were nonexistent or that payments were returned.
Professional fees paid for services linked to imports from OFAC-restricted Iranian-origin goods were held allowable under section 37(1) because the assessee proved the recipient's identity, genuineness of payment, and banking trail, while the payee confirmed the transactions and disclosed them in its tax records. The Tribunal accepted that the services addressed abnormal remittance delays caused by OFAC-related banking scrutiny, and that comparative material showed improved payment cycles, turnover, and profits after the services were used. Revenue's disallowance failed because it relied on suspicion without independent enquiry or evidence that the services were nonexistent or that payments were returned.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4817 
Join Channel 
