Political contribution deductions require assessee-specific proof before cash-back allegations can justify disallowance or unexplained-money additions...
TP Adjustment - Adjustment in respect of credit period - the contentions of Revenue and Assessee have not been thoroughly examined by the Ld. CIT(A) in proper perspective. We also observe that no remand report was called for by the Ld. CIT(A) to appreciate the contentions of Revenue as well as the Assessee. In the interest of justice we restore this ground to the file of the Ld. AO/TPO for denovo adjudication in accordance with law after providing adequate opportunity of being heard to the assessee. Grounds of appeal of the Revenue is allowed for statistical purpose. - AT
TP Adjustment - Adjustment in respect of credit period - the contentions of Revenue and Assessee have not been thoroughly examined by the Ld. CIT(A) in proper perspective. We also observe that no remand report was called for by the Ld. CIT(A) to appreciate the contentions of Revenue as well as the Assessee. In the interest of justice we restore this ground to the file of the Ld. AO/TPO for denovo adjudication in accordance with law after providing adequate opportunity of being heard to the assessee. Grounds of appeal of the Revenue is allowed for statistical purpose. - AT
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