Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Addition u/s 68 cannot be made solely based on sworn statement recorded u/s 132(4) without corroborative materials. Onus lies on the Department to collect cogent evidence to corroborate notings on loose sheets. Additions cannot be made based on assumptions, suspicions, or irrelevant inadmissible material. Capital gains should be taxed on actual gains, not fictional income. Unless evidence shows more was received than stated, no higher price can be the basis for addition. Issue remitted to Assessing Officer to re-examine if ingredients of section 68 are present based on corroborative seized material, not statements u/s 132(4) or 131. For section 69B and 69C additions in assessment years 2017-18 and 2018-19, additions based on unsubstantiated seized material and statements u/s 132(4) cannot be sustained. Accordingly, additions deleted.
Addition u/s 68 cannot be made solely based on sworn statement recorded u/s 132(4) without corroborative materials. Onus lies on the Department to collect cogent evidence to corroborate notings on loose sheets. Additions cannot be made based on assumptions, suspicions, or irrelevant inadmissible material. Capital gains should be taxed on actual gains, not fictional income. Unless evidence shows more was received than stated, no higher price can be the basis for addition. Issue remitted to Assessing Officer to re-examine if ingredients of section 68 are present based on corroborative seized material, not statements u/s 132(4) or 131. For section 69B and 69C additions in assessment years 2017-18 and 2018-19, additions based on unsubstantiated seized material and statements u/s 132(4) cannot be sustained. Accordingly, additions deleted.
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