Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
Cooperative society deposits, member-interest TDS exemption and credit-facility deduction claims require verification through records and supporting e...
Customs jurisdiction over EPCG condition breaches survives export-obligation discharge certificates, requiring alleged fraud and misdeclaration to be ...
Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
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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