Restricted silver imports may clear under a valid import authorisation without additional status or exchange-routing requirements unless expressly imp...
Head Office cost allocation requires prescribed transfer-pricing methods; treaty ceilings bar surcharge and cess, while duplicate taxation is excluded...
Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
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 4905 
