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...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
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Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
The ITAT Ahmedabad addressed various issues. On the 40(a)(ia) addition, the assessee failed to provide necessary details justifying deductions disallowed in earlier years due to non-TDS deduction. The Tribunal emphasized the need for supporting documents and allowed deductions on actual payment basis. Regarding u/s 36(1)(va), the Tribunal dismissed the appeal based on a precedent. For unsecured loan waiver, the Tribunal held that waiver of loan is not taxable u/s 28(iv) as it's a cash benefit. The Tribunal directed deletion of the addition u/s 41(1) as neither the AO nor CIT(A) invoked this provision. The assessee was granted another opportunity to present their case before the AO.
The ITAT Ahmedabad addressed various issues. On the 40(a)(ia) addition, the assessee failed to provide necessary details justifying deductions disallowed in earlier years due to non-TDS deduction. The Tribunal emphasized the need for supporting documents and allowed deductions on actual payment basis. Regarding u/s 36(1)(va), the Tribunal dismissed the appeal based on a precedent. For unsecured loan waiver, the Tribunal held that waiver of loan is not taxable u/s 28(iv) as it's a cash benefit. The Tribunal directed deletion of the addition u/s 41(1) as neither the AO nor CIT(A) invoked this provision. The assessee was granted another opportunity to present their case before the AO.
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