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Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
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Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
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Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
Additions for alleged unaccounted admission fees based on seized loose sheets, visitors' slips and diary entries require adequate corroboration. Material relating to specific years cannot support extrapolated additions for other years, and estimated suppression of fees for remaining seats cannot rest on unsupported assumptions. For cancellation seats, an assumption of management-quota fee collection was unsupported where admissions were governed by an agreement restricting fees and admission records were produced. The HC upheld deletion of the additions, finding that the Revenue had not shown perversity in the Tribunal's factual findings. Under section 260A, the HC cannot reappreciate evidence or substitute factual conclusions absent findings based on no evidence or perversity. Exemption issues were left open.
Additions for alleged unaccounted admission fees based on seized loose sheets, visitors' slips and diary entries require adequate corroboration. Material relating to specific years cannot support extrapolated additions for other years, and estimated suppression of fees for remaining seats cannot rest on unsupported assumptions. For cancellation seats, an assumption of management-quota fee collection was unsupported where admissions were governed by an agreement restricting fees and admission records were produced. The HC upheld deletion of the additions, finding that the Revenue had not shown perversity in the Tribunal's factual findings. Under section 260A, the HC cannot reappreciate evidence or substitute factual conclusions absent findings based on no evidence or perversity. Exemption issues were left open.
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