Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
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...
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An ITAT deleted an addition under section 69C for alleged on-money payment because the assessment rested only on an investigation report, a seized excel sheet naming another person, and a general builder's employee statement. The assessee's banking-channel payment evidence was not rebutted, and no independent corroboration of cash payment was brought on record. The third-party statement was untested by cross-examination and could not, by itself, sustain the addition. The appeal was partly allowed.
An ITAT deleted an addition under section 69C for alleged on-money payment because the assessment rested only on an investigation report, a seized excel sheet naming another person, and a general builder's employee statement. The assessee's banking-channel payment evidence was not rebutted, and no independent corroboration of cash payment was brought on record. The third-party statement was untested by cross-examination and could not, by itself, sustain the addition. The appeal was partly allowed.
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