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 u/s 69A - cash loans given by the assessee as unexplained - decoding of the entries in the seized materials - The tribunal found that the assessing officer's reliance on statements recorded during the search was insufficient to justify the addition under section 69A. They emphasized that the assessing officer did not entertain the appellant's request for cross-examination, and the retracted statements raised doubts about their reliability. Additionally, the tribunal noted discrepancies in the interpretation of entries and the lack of concrete evidence connecting the appellant to the transactions. Therefore, they deemed the addition unjustified and deleted it.
Addition u/s 69A - cash loans given by the assessee as unexplained - decoding of the entries in the seized materials - The tribunal found that the assessing officer's reliance on statements recorded during the search was insufficient to justify the addition under section 69A. They emphasized that the assessing officer did not entertain the appellant's request for cross-examination, and the retracted statements raised doubts about their reliability. Additionally, the tribunal noted discrepancies in the interpretation of entries and the lack of concrete evidence connecting the appellant to the transactions. Therefore, they deemed the addition unjustified and deleted it.
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