Social forestry expenditure requires activity-based classification, limiting book-profit adjustments and preserving penalty relief where normal additi...
Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Customs Broker due diligence requires prescribed KYC, not detecting misdeclarations discoverable only through physical examination, defeating licence ...
The Appellate Tribunal addressed several issues. Regarding quantification of profit element on unsubstantiated purchases, the matter was sent back to the Assessing Officer (\u/s) for limited addition based on profit rate variance. Disallowance of interest on loan was allowed for further evidence consideration. Addition \u/s 68 for unsecured loans was revisited due to new documents submitted, leading to a direction for reassessment by the AO. The assessee's appeals were allowed for statistical purposes. The AO was instructed to provide a fair opportunity for the assessee in each case.
The Appellate Tribunal addressed several issues. Regarding quantification of profit element on unsubstantiated purchases, the matter was sent back to the Assessing Officer (\u/s) for limited addition based on profit rate variance. Disallowance of interest on loan was allowed for further evidence consideration. Addition \u/s 68 for unsecured loans was revisited due to new documents submitted, leading to a direction for reassessment by the AO. The assessee's appeals were allowed for statistical purposes. The AO was instructed to provide a fair opportunity for the assessee in each case.
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