Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
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...
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The ITAT Delhi, in an assessment u/s 153A, addressed the addition u/s 68 concerning income from undisclosed sources. The appellant, a partner in M/s. RNB Leasing and Financial Services, had filed a return for the assessment year. Following search and seizure operations, a key to an Indian Overseas Bank locker was found in the names of Lalita Bajaj and the appellant. Despite no incriminating evidence found during the search of the locker, the AO made additions u/s 68 in a similar case involving share allotment. However, in the present case, the appellant did not receive share application money or premium but was involved in the sale of investments/shares to other entities. The Department did not dispute the investment in shares during the earlier period. The ITAT allowed the appellant's grounds on merits, distinguishing the case from previous rulings.
The ITAT Delhi, in an assessment u/s 153A, addressed the addition u/s 68 concerning income from undisclosed sources. The appellant, a partner in M/s. RNB Leasing and Financial Services, had filed a return for the assessment year. Following search and seizure operations, a key to an Indian Overseas Bank locker was found in the names of Lalita Bajaj and the appellant. Despite no incriminating evidence found during the search of the locker, the AO made additions u/s 68 in a similar case involving share allotment. However, in the present case, the appellant did not receive share application money or premium but was involved in the sale of investments/shares to other entities. The Department did not dispute the investment in shares during the earlier period. The ITAT allowed the appellant's grounds on merits, distinguishing the case from previous rulings.
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