Social forestry expenditure requires activity-based classification, limiting book-profit adjustments and preserving penalty relief where normal additi...
Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Customs Broker due diligence requires prescribed KYC, not detecting misdeclarations discoverable only through physical examination, defeating licence ...
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Revision u/s 263 - Addition u/s 68 r.w.s. 115BBE - no verification of ‘other income’ was done by Ld. AO. In fact during revisional proceedings, the assessee shifted the stand and submitted that it was surplus out of deposits and withdrawals which are contradictory to return of income. It is clear that the nature and source of Rs.7.55 Lacs was nowhere examined by Ld. AO as well as no explanation for the same was furnished by the assessee. Under such circumstances, the revision was justified. - AT
Revision u/s 263 - Addition u/s 68 r.w.s. 115BBE - no verification of ‘other income’ was done by Ld. AO. In fact during revisional proceedings, the assessee shifted the stand and submitted that it was surplus out of deposits and withdrawals which are contradictory to return of income. It is clear that the nature and source of Rs.7.55 Lacs was nowhere examined by Ld. AO as well as no explanation for the same was furnished by the assessee. Under such circumstances, the revision was justified. - AT
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