Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
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When the Revenue alleged receipt of accommodation entries through bogus billing, the onus remained on it to prove the impugned transaction with reliable evidence, and the addition could not rest on unverified investigation material. The assessee explained that there was no purchase or sale with the concern during the year and that the receipts were towards earlier outstanding dues, supported by its ledger account; the Revenue did not disprove that explanation or establish the alleged entry in the assessee's case. Reliance on an undisclosed statement, without supplying it to the assessee or granting cross-examination, also breached natural justice. The ITAT therefore deleted the entire addition.
When the Revenue alleged receipt of accommodation entries through bogus billing, the onus remained on it to prove the impugned transaction with reliable evidence, and the addition could not rest on unverified investigation material. The assessee explained that there was no purchase or sale with the concern during the year and that the receipts were towards earlier outstanding dues, supported by its ledger account; the Revenue did not disprove that explanation or establish the alleged entry in the assessee's case. Reliance on an undisclosed statement, without supplying it to the assessee or granting cross-examination, also breached natural justice. The ITAT therefore deleted the entire addition.
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