Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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WhatsApp messages used to support an alleged cash transaction were held insufficient without corroboration, so the related addition was deleted. Additions based on a retracted search statement and a third-party statement were also unsustainable where the assessee sought copies of material and cross-examination, but no proper evidentiary foundation or independent enquiry was made. Income already returned and taxed in the spouse's hands could not be taxed again as the assessee's undisclosed income. For agricultural income, the Tribunal accepted documentary support and upheld only a limited estimate rather than the full addition. Additions based on presumed agricultural income of family members were likewise rejected for want of evidence.
WhatsApp messages used to support an alleged cash transaction were held insufficient without corroboration, so the related addition was deleted. Additions based on a retracted search statement and a third-party statement were also unsustainable where the assessee sought copies of material and cross-examination, but no proper evidentiary foundation or independent enquiry was made. Income already returned and taxed in the spouse's hands could not be taxed again as the assessee's undisclosed income. For agricultural income, the Tribunal accepted documentary support and upheld only a limited estimate rather than the full addition. Additions based on presumed agricultural income of family members were likewise rejected for want of evidence.
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