Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
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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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