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...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Addition u/s 68 - unsecured loans Addition u/s 2(22)(e) - Deemed dividend - The Tribunal found merit in the Assessee's submissions, noting that all relevant documents were submitted to prove the legitimacy of the transaction. The addition under section 68 was reversed, and the AO was directed to delete the same. However, the addition under section 2(22)(e) was upheld, as the Assessee failed to provide substantial evidence to support the contention that the loan from M/s KAJ Infrastructure Pvt. Ltd. was for business purposes.
Addition u/s 68 - unsecured loans Addition u/s 2(22)(e) - Deemed dividend - The Tribunal found merit in the Assessee's submissions, noting that all relevant documents were submitted to prove the legitimacy of the transaction. The addition under section 68 was reversed, and the AO was directed to delete the same. However, the addition under section 2(22)(e) was upheld, as the Assessee failed to provide substantial evidence to support the contention that the loan from M/s KAJ Infrastructure Pvt. Ltd. was for business purposes.
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