Search-related assessment framework governs post-search proceedings, while evidentiary burdens shape loan, cash, and transfer-pricing adjustments.
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....Search-related assessments initiated on or after 1 April 2021 must proceed under the reassessment framework, rather than regular scrutiny assessment provisions. Where seized material belongs to a third party, the Assessing Officer must record satisfaction that it pertains to the assessee and obtain prescribed approval; non-compliance can invalidate the assessment. For unsecured loans, identity, creditworthiness and genuineness may be established through corporate, financial, banking, confirmation and repayment records, while untested third-party statements cannot alone support additions. Transfer-pricing analysis should respect accepted guarantee-pricing methods and avoid separate interest adjustments where delayed receivables are already r.........
TaxTMI