Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
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Assessment u/s 153A - addition u/s 68 - The assessee contended that the additions were not based on any incriminating material found during the search. The Tribunal held that no addition could be made under Section 153A in the absence of incriminating material for the years where no assessment was pending. The court accepted this contention and deleted the additions. - The ITAT examined several additions and disallowances made by the assessing officer, including those related to cash deposits, unsecured loans, and depreciation on vehicles. In each instance, the court meticulously evaluated the submissions, documentary evidence, and legal positions before rendering its decisions, often in favor of the assessee by deleting unjustified additions.
Assessment u/s 153A - addition u/s 68 - The assessee contended that the additions were not based on any incriminating material found during the search. The Tribunal held that no addition could be made under Section 153A in the absence of incriminating material for the years where no assessment was pending. The court accepted this contention and deleted the additions. - The ITAT examined several additions and disallowances made by the assessing officer, including those related to cash deposits, unsecured loans, and depreciation on vehicles. In each instance, the court meticulously evaluated the submissions, documentary evidence, and legal positions before rendering its decisions, often in favor of the assessee by deleting unjustified additions.
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