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...
An addition for unexplained investment cannot be sustained unless the investment was made in the financial year immediately preceding the relevant assessment year. Here, the ledger accounts and year-wise expenditure charts showed that the opening work-in-progress consisted of expenditure incurred over several earlier years, and the Revenue itself treated it as a prior-period balance. The Assessing Officer could not tax that historical investment in the current year merely because earlier returns were filed on a non-business basis or because prior disclosure was allegedly incomplete. The addition under Section 69 was therefore unsustainable and was deleted.
An addition for unexplained investment cannot be sustained unless the investment was made in the financial year immediately preceding the relevant assessment year. Here, the ledger accounts and year-wise expenditure charts showed that the opening work-in-progress consisted of expenditure incurred over several earlier years, and the Revenue itself treated it as a prior-period balance. The Assessing Officer could not tax that historical investment in the current year merely because earlier returns were filed on a non-business basis or because prior disclosure was allegedly incomplete. The addition under Section 69 was therefore unsustainable and was deleted.
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