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...
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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