Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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In the case, ITAT decided on two main issues: 1. Addition on account of Gold and Silver Jewellery u/s 69A: Assessee disclosed Rs. 70,00,000 as unexplained investment during search. ITAT found the disclosed gold and silver quantities reasonable based on CBDT guidelines. Assessee declared gold ornaments and silver items in HUF for deduction. ITAT directed AO to delete Rs. 28,96,104 addition. 2. Addition of cash found u/s 69A: Assessee explained Rs. 1,50,000 belonged to M/s. Sarvodaya Agrotech. AO added Rs. 3 lac cash found. CIT(A) sustained Rs. 2 lac addition, considering savings of Rs. 2 lac. ITAT found no merit in sustaining Rs. 2 lac addition, as assessee cooperated, disclosed income, and had wealth tax history. ITAT directed AO to delete the Rs. 2 lac cash addition.
In the case, ITAT decided on two main issues: 1. Addition on account of Gold and Silver Jewellery u/s 69A: Assessee disclosed Rs. 70,00,000 as unexplained investment during search. ITAT found the disclosed gold and silver quantities reasonable based on CBDT guidelines. Assessee declared gold ornaments and silver items in HUF for deduction. ITAT directed AO to delete Rs. 28,96,104 addition. 2. Addition of cash found u/s 69A: Assessee explained Rs. 1,50,000 belonged to M/s. Sarvodaya Agrotech. AO added Rs. 3 lac cash found. CIT(A) sustained Rs. 2 lac addition, considering savings of Rs. 2 lac. ITAT found no merit in sustaining Rs. 2 lac addition, as assessee cooperated, disclosed income, and had wealth tax history. ITAT directed AO to delete the Rs. 2 lac cash addition.
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