Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
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The ITAT held that alleged documents of bank account with HSBC London were genuine as the assessee accepted and revised the return. Absence of incriminating material in search operation supported revenue's actions. Indo-UK DTAA Article 23(3) not applicable as source of deposits not established. AO's reference to FT&TR for info from UK valid. Accrued interest additions not sustainable due to lack of evidence beyond sourced statement. Penalty u/s 271(1)(c) not justified as no misreporting found. Increased penalty by CIT(A) also deleted. Other penalties on interest income deleted. Addition based on loose sheets dismissed as lacking evidentiary value. All grounds raised by assessee allowed.
The ITAT held that alleged documents of bank account with HSBC London were genuine as the assessee accepted and revised the return. Absence of incriminating material in search operation supported revenue's actions. Indo-UK DTAA Article 23(3) not applicable as source of deposits not established. AO's reference to FT&TR for info from UK valid. Accrued interest additions not sustainable due to lack of evidence beyond sourced statement. Penalty u/s 271(1)(c) not justified as no misreporting found. Increased penalty by CIT(A) also deleted. Other penalties on interest income deleted. Addition based on loose sheets dismissed as lacking evidentiary value. All grounds raised by assessee allowed.
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