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...
Addition of contract receipts - bogus activity - Estimation of income - The AO had made an addition to the assessee's income, alleging discrepancies in the contract receipts and estimating the profit at 8%. However, upon careful consideration, the Tribunal found inconsistencies in the assessment. It questioned the basis for estimating profit at 8% when the commission ranged from 0.25% to 1%, and the discrepancy regarding the actual contract receipts. The Tribunal concluded that the addition lacked demonstrative evidence and was based on surmise and conjecture.
Addition of contract receipts - bogus activity - Estimation of income - The AO had made an addition to the assessee's income, alleging discrepancies in the contract receipts and estimating the profit at 8%. However, upon careful consideration, the Tribunal found inconsistencies in the assessment. It questioned the basis for estimating profit at 8% when the commission ranged from 0.25% to 1%, and the discrepancy regarding the actual contract receipts. The Tribunal concluded that the addition lacked demonstrative evidence and was based on surmise and conjecture.
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