Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes...
Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
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The assessee's appeal was allowed and the addition was deleted. The authorities failed to analyze the assessee's specific stand and incorrectly assumed availability of unexplained cash credit. The AO's findings regarding abnormal cash deposit trend during demonetization and earlier months were incorrect, as demonstrated by the assessee's tabulated details showing gradual increase in turnover. The AO did not visualize the circumstances during demonetization, where all amounts had to be routed through bank accounts. The CIT(A) reduced the quantum addition but adopted a different analogy, calculating cash availability based on turnover increase without analyzing purchases and resulting profit. The ITAT held that the addition was unsustainable, as the authorities did not examine whether the profit ratio could be swindled to that magnitude, and books of account should not have been rejected.
The assessee's appeal was allowed and the addition was deleted. The authorities failed to analyze the assessee's specific stand and incorrectly assumed availability of unexplained cash credit. The AO's findings regarding abnormal cash deposit trend during demonetization and earlier months were incorrect, as demonstrated by the assessee's tabulated details showing gradual increase in turnover. The AO did not visualize the circumstances during demonetization, where all amounts had to be routed through bank accounts. The CIT(A) reduced the quantum addition but adopted a different analogy, calculating cash availability based on turnover increase without analyzing purchases and resulting profit. The ITAT held that the addition was unsustainable, as the authorities did not examine whether the profit ratio could be swindled to that magnitude, and books of account should not have been rejected.
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