Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
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...
Estimation of income - Bogus purchases - Reliance on retracted statement - The ITAT, after reviewing the case, noted discrepancies in the reliance on these statements for making disallowances. They observed that subsequent affidavits retracted these statements, diminishing their evidentiary value. Additionally, documentary evidence such as invoices and bank statements corroborated the assessee's claims of genuine purchases. For several assessment years, the tribunal decided to delete the disallowances concerning bogus purchases, arguing that the AO's assessments were based on inadequate grounds and, in some cases, relied excessively on ad-hoc estimates.
Estimation of income - Bogus purchases - Reliance on retracted statement - The ITAT, after reviewing the case, noted discrepancies in the reliance on these statements for making disallowances. They observed that subsequent affidavits retracted these statements, diminishing their evidentiary value. Additionally, documentary evidence such as invoices and bank statements corroborated the assessee's claims of genuine purchases. For several assessment years, the tribunal decided to delete the disallowances concerning bogus purchases, arguing that the AO's assessments were based on inadequate grounds and, in some cases, relied excessively on ad-hoc estimates.
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