Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Revision u/s 263 - Genuineness of expenditure (Commission paid) - The ITAT found that the commission agreement was genuine, payments were made through banking channels, and tax was deducted at source, supporting the legitimacy of the transaction. Despite the substantial amount of commission paid, the ITAT emphasized that the genuineness of the transaction should be verified, which was found to be in order. The discrepancy in GST calculations and reported figures was deemed irrelevant by the ITAT. - The ITAT allowed the appeal of the assessee, quashing the order passed by the Ld. Pr. CIT under Section 263.
Revision u/s 263 - Genuineness of expenditure (Commission paid) - The ITAT found that the commission agreement was genuine, payments were made through banking channels, and tax was deducted at source, supporting the legitimacy of the transaction. Despite the substantial amount of commission paid, the ITAT emphasized that the genuineness of the transaction should be verified, which was found to be in order. The discrepancy in GST calculations and reported figures was deemed irrelevant by the ITAT. - The ITAT allowed the appeal of the assessee, quashing the order passed by the Ld. Pr. CIT under Section 263.
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TaxTMI 
TaxTMI 
