Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Protective addition on account of unexplained credit entries appearing in the bank account - assessee company is a conduit - addition on account of unaccounted commission @ 0.25 % of total unexplained credit entries - The CIT(A) had deleted these additions, finding that the assessee acted as a conduit for accommodation entries, with identified beneficiaries, thus no further addition was warranted in the assessee's hands. The ITAT upheld the CIT(A)'s decision, noting that since the assessee operated as a conduit managed by certain individuals for providing accommodation entries, no addition for commission income was justified.
Protective addition on account of unexplained credit entries appearing in the bank account - assessee company is a conduit - addition on account of unaccounted commission @ 0.25 % of total unexplained credit entries - The CIT(A) had deleted these additions, finding that the assessee acted as a conduit for accommodation entries, with identified beneficiaries, thus no further addition was warranted in the assessee's hands. The ITAT upheld the CIT(A)'s decision, noting that since the assessee operated as a conduit managed by certain individuals for providing accommodation entries, no addition for commission income was justified.
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