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 on the basis of declaration made by assessee during a search action u/s 132 - The ITAT found no merit in the revenue's arguments, noting that the addition was based solely on the assessee's statement during the search. The ITAT emphasized that under the scheme of Income-tax, only the correct income should be taxed, and the CBDT instruction dated 10.03.2003 restricts making additions based on mere confessions during search/survey without corroborative evidence. The ITAT concluded that the addition made by the revenue authorities was not justified and ordered its deletion.
Addition on the basis of declaration made by assessee during a search action u/s 132 - The ITAT found no merit in the revenue's arguments, noting that the addition was based solely on the assessee's statement during the search. The ITAT emphasized that under the scheme of Income-tax, only the correct income should be taxed, and the CBDT instruction dated 10.03.2003 restricts making additions based on mere confessions during search/survey without corroborative evidence. The ITAT concluded that the addition made by the revenue authorities was not justified and ordered its deletion.
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