Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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Addition u/s 69A - unexplained cash deposits in the bank account - onus to prove - The Tribunal noted that the appellant had provided evidence to support the source of cash deposits, demonstrating legitimate cash withdrawals preceding the deposits. It concluded that the Assessing Officer had not presented any adverse material to refute the appellant's claims. Therefore, the Tribunal directed the AO to delete the impugned addition under section 69A.
Addition u/s 69A - unexplained cash deposits in the bank account - onus to prove - The Tribunal noted that the appellant had provided evidence to support the source of cash deposits, demonstrating legitimate cash withdrawals preceding the deposits. It concluded that the Assessing Officer had not presented any adverse material to refute the appellant's claims. Therefore, the Tribunal directed the AO to delete the impugned addition under section 69A.
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