Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
Undisclosed income of the assessee - bogus sale of agricultural produce - preponderance of probability theory - The Tribunal noted that the AO had not properly considered the nature of the appellant’s income and the agricultural evidence provided. It was observed that the lower authorities failed to appreciate the complexities of agricultural income and its proof, particularly in light of the transactions during the demonetization period. - The statements recorded by the AO, including those of a person responsible for the appellant's agricultural affairs, did not conclusively prove that the agricultural receipts were manipulated. - The Tribunal allowed the appeal, setting aside the addition of income.
Undisclosed income of the assessee - bogus sale of agricultural produce - preponderance of probability theory - The Tribunal noted that the AO had not properly considered the nature of the appellant’s income and the agricultural evidence provided. It was observed that the lower authorities failed to appreciate the complexities of agricultural income and its proof, particularly in light of the transactions during the demonetization period. - The statements recorded by the AO, including those of a person responsible for the appellant's agricultural affairs, did not conclusively prove that the agricultural receipts were manipulated. - The Tribunal allowed the appeal, setting aside the addition of income.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
