Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Remittances to Indian NRE accounts were held explained where the assessee produced tax residency certificates, foreign tax returns, bank statements and Indian account records showing long-standing foreign income and accumulated savings. The Tribunal found that the funds were transferred through banking channels with a direct nexus to the foreign bank account, so the explanation could not be rejected merely for non-compliance at assessment stage or for comparing remittances with the wrong income period. Because the remittances were satisfactorily explained, the linked investment in immovable property was also not treated as unexplained. The additions under section 69 were deleted.
Remittances to Indian NRE accounts were held explained where the assessee produced tax residency certificates, foreign tax returns, bank statements and Indian account records showing long-standing foreign income and accumulated savings. The Tribunal found that the funds were transferred through banking channels with a direct nexus to the foreign bank account, so the explanation could not be rejected merely for non-compliance at assessment stage or for comparing remittances with the wrong income period. Because the remittances were satisfactorily explained, the linked investment in immovable property was also not treated as unexplained. The additions under section 69 were deleted.
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