Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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The Appellate Tribunal held that the addition of Rs. 51.20 lacs as unexplained investment u/ss 69 or 56(2)(x)/6(2)(vii) was unjustified as there was no evidence of actual payment to vendors. Section 69 requires actual investment, not just stamp value. The lower authorities erred in making the addition, which is not taxable for a partnership firm u/s 56(2)(x) for the relevant assessment year. The decision favored the assessee, and the appeal was allowed.
The Appellate Tribunal held that the addition of Rs. 51.20 lacs as unexplained investment u/ss 69 or 56(2)(x)/6(2)(vii) was unjustified as there was no evidence of actual payment to vendors. Section 69 requires actual investment, not just stamp value. The lower authorities erred in making the addition, which is not taxable for a partnership firm u/s 56(2)(x) for the relevant assessment year. The decision favored the assessee, and the appeal was allowed.
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