Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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The Appellate Tribunal held that the addition u/s 56(2)(vii) or 28(iv) was unjustified, as the purchase was made with consideration, cheques were given to sellers with some not cleared due to property litigation. The addition u/s 69 for unexplained deposits was deleted, as cash withdrawals from one bank provided a source for deposits in another, AO's reasons were vague. The addition for cash-receipts as unexplained was also deleted, as taxable receipts were part of sale-proceeds duly assessed. Addition on account of cash-receipt for Godamaru was deleted, as money was refunded due to deal cancellation. The issue of advance for Badwai was remitted to AO for verification in a subsequent assessment year.
The Appellate Tribunal held that the addition u/s 56(2)(vii) or 28(iv) was unjustified, as the purchase was made with consideration, cheques were given to sellers with some not cleared due to property litigation. The addition u/s 69 for unexplained deposits was deleted, as cash withdrawals from one bank provided a source for deposits in another, AO's reasons were vague. The addition for cash-receipts as unexplained was also deleted, as taxable receipts were part of sale-proceeds duly assessed. Addition on account of cash-receipt for Godamaru was deleted, as money was refunded due to deal cancellation. The issue of advance for Badwai was remitted to AO for verification in a subsequent assessment year.
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