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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Addition treated as unexplained cash credit on an unsecured loan was deleted because the lender's identity, creditworthiness based on its financials, and the genuineness of the loan transaction from an NBFC had already been accepted on identical facts in a coordinate Bench decision. The Tribunal held that the Commissioner (Appeals) had sustained the addition mainly by relying on an order in a group concern's case involving the same lender, but that foundation no longer survived after the earlier order was reversed. Applying the same reasoning, the loan from M/s Sundram Consultants Pvt. Ltd. was not liable to be assessed as unexplained cash credit.
Addition treated as unexplained cash credit on an unsecured loan was deleted because the lender's identity, creditworthiness based on its financials, and the genuineness of the loan transaction from an NBFC had already been accepted on identical facts in a coordinate Bench decision. The Tribunal held that the Commissioner (Appeals) had sustained the addition mainly by relying on an order in a group concern's case involving the same lender, but that foundation no longer survived after the earlier order was reversed. Applying the same reasoning, the loan from M/s Sundram Consultants Pvt. Ltd. was not liable to be assessed as unexplained cash credit.
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