Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
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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