Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
Automotive radio classification treats integrated infotainment features as supplementary, placing complete and qualifying unassembled units under the ...
Separate corporate personality prevents directors from being personally liable for company deposits without a guarantee or independent legal undertaki...
Cross-segment derivatives manipulation: integrated order patterns can support interim restraints, while director liability requires responsibility, co...
Investigation material linking three loan creditors to accommodation-entry providers, supported by admissions concerning management of bank accounts and income-tax files, established a sufficient nexus for reassessment; the challenge to reopening failed. Confirmations and bank records showing full repayment in the following financial year, together with no corresponding addition for loans from the same creditors in the succeeding year, meant the loans could not be treated as accommodation entries. The Tribunal deleted the bogus-loan addition, and the consequential unexplained-expenditure addition did not survive; the appeal was partly allowed.
Investigation material linking three loan creditors to accommodation-entry providers, supported by admissions concerning management of bank accounts and income-tax files, established a sufficient nexus for reassessment; the challenge to reopening failed. Confirmations and bank records showing full repayment in the following financial year, together with no corresponding addition for loans from the same creditors in the succeeding year, meant the loans could not be treated as accommodation entries. The Tribunal deleted the bogus-loan addition, and the consequential unexplained-expenditure addition did not survive; the appeal was partly allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4910 
