income, Audit report, Bank
statements, Partnership deed, Confirmation of capital introduced
with supporting documents, Fund flow statement and Source and
proof of investment in property ... record
sufficiently explains the source of capital introduced by the
partners. Reference was made to the following documents:
i. Financial statements of the partners placed
erred in:
2
2.1. Disregarding the transfer pricing documentation maintained by
the Appellant as per Section 92D of the Act and the benchmarking
analysis undertaken ... documentation;
2.4. Disregarding certain filters as applied by the Appellant in
selection of the comparable companies at the time of TP
documentation.
2.5. Introducing/modifying
analysis carried out by the
Assessee in the Transfer Pricing Documentation ("TP
Documentation') and arbitrary applying incorrect
quantitative filters without providing any cogent ... Assessee in the TP Documentation basis the provisions of
Rule 10B(2) of the Rules;
1.3 introducing additional companies without appreciating
that such companies
Section 44C was introduced to eliminate/
expenses under Section 44C - minimize the burden of maintenance of
of the Act documentation in respect of head office ... under:
1) Section 44C was introduced to eliminate/ minimize the burden of
maintenance of documentation in respect of head office expenses.
Reliance is placed
examined based on other evidences. In this regard, the details of documents
filed by the assesses before the Investigation Unit, survey party and the
assessing ... attempt at introducing unaccounted cash into its own
books through loan entries. The assessee has filed various documents including
the bank account extracts
bank and held that as per the documents provided by the bank the CMD had
introduced DJS as one of the directors of the company
Acc Ltd., Mumbai vs Addl Cit(Ltu) , Mumbai on 28 February, 2023
IN THE INCOME
provide such primary documents. It only provides
perfunctory, make believe kind of documents to justify a self-
serving argument. The documents produced serve the purpose ... purpose of introducing section
68 in the provisions of the Act. All that the DDIT/Α.Ο. were
expecting was documents to prove
amount paid/allowed was in the name of the payee-company, for
introducing clients, whose details were given, along with the copy of the bill ... unless the meeting/s (i.e., between the parties introduced and
the middleman) is documented and minutes thereof recorded, and which has not been
showing the period, No. of members
made/introduced by Shri Vinod Jaiswal, page No. of seized documents,
page No. of assessee's paper book
