Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
The ITAT, an Appellate Tribunal, addressed the validity of reopening assessment u/s 147 and addition u/s 68. The AO had sufficient material to believe the assessee introduced unaccounted income as bogus share capital, leading to income escapement. The notice u/s 147 was upheld as valid. The assessee failed to prove creditworthiness of share applicant or transaction genuineness. AO's addition u/s 68 was deemed justified, concluding the assessee channeled its own funds through investor companies. The assessee engaged in dubious activities, introducing unaccounted money through questionable transactions. The CIT(A)'s order was upheld, ruling against the assessee.
The ITAT, an Appellate Tribunal, addressed the validity of reopening assessment u/s 147 and addition u/s 68. The AO had sufficient material to believe the assessee introduced unaccounted income as bogus share capital, leading to income escapement. The notice u/s 147 was upheld as valid. The assessee failed to prove creditworthiness of share applicant or transaction genuineness. AO's addition u/s 68 was deemed justified, concluding the assessee channeled its own funds through investor companies. The assessee engaged in dubious activities, introducing unaccounted money through questionable transactions. The CIT(A)'s order was upheld, ruling against the assessee.
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