Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
Preventive suspension requires an immediate continuing threat and cannot become indefinite without inquiry, fresh evidence, or proportionate safeguard...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4792
Join Channel
TaxTMI 
