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External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Addition based on entries appearing in a diary seized from the assessee - Penalty proceedings u/s. 269SS, 269T and 271AAB - The CIT(A) held that the AO's findings were not sustainable as they lacked material evidence and reasoning. The CIT(A) noted that the transactions in the seized diary were related to the partnership firms' projects, and the assessee was maintaining accounts for the partners of these firms. The CIT(A) also considered the disclosure made by the partnership firms while deciding the penalty. - The ITAT dismissed the appeal filed by the Revenue, affirming the CIT(A)'s order.
Addition based on entries appearing in a diary seized from the assessee - Penalty proceedings u/s. 269SS, 269T and 271AAB - The CIT(A) held that the AO's findings were not sustainable as they lacked material evidence and reasoning. The CIT(A) noted that the transactions in the seized diary were related to the partnership firms' projects, and the assessee was maintaining accounts for the partners of these firms. The CIT(A) also considered the disclosure made by the partnership firms while deciding the penalty. - The ITAT dismissed the appeal filed by the Revenue, affirming the CIT(A)'s order.
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