SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
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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