Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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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