Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
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ITAT deleted the addition in the firm's hands for partners' capital contribution under section 68, holding that once the firm furnished the source of capital and the partners confirmed the contribution, its onus stood discharged; any further inquiry into creditworthiness had to be made against the partners, not the firm. On unsecured loans from two creditors, the Tribunal found the assessee's version of banking-channel receipts and later repayment with interest required verification of bank entries and repayment evidence. That issue was remanded to the Assessing Officer for fresh adjudication, with no addition indicated if repayment was established. The appeal was thus allowed for statistical purposes.
ITAT deleted the addition in the firm's hands for partners' capital contribution under section 68, holding that once the firm furnished the source of capital and the partners confirmed the contribution, its onus stood discharged; any further inquiry into creditworthiness had to be made against the partners, not the firm. On unsecured loans from two creditors, the Tribunal found the assessee's version of banking-channel receipts and later repayment with interest required verification of bank entries and repayment evidence. That issue was remanded to the Assessing Officer for fresh adjudication, with no addition indicated if repayment was established. The appeal was thus allowed for statistical purposes.
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