Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
Food import sampling requirements support provisional release where unseized consignments conform to standards and raw areca classification is unestab...
Diagnostic microcuvette classification follows sole-use analytical function, placing specialised disposable cuvettes with their analyser rather than g...
Customs Broker licensing proceedings fail when their offence-report foundation collapses and authorisation, advisory, and KYC duties remain unbreached...
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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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