Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
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The case pertains to the addition of undisclosed income u/s 69A of the Income Tax Act, wherein the peak credit method was applied. The Commissioner of Income Tax (Appeals) [CIT(A)] was satisfied with the assessee's business activities and cash collections deposited in bank accounts. The CIT(A) reproduced the details of the peak credit, considering opening balances in bank accounts, cash, advances, income from money lending business, and drawings. The CIT(A) determined the unexplained amount after deducting the net fund available from the peak credit. The CIT(A) relied on the decision of the Madras High Court in the case of PCIT v. S. Anbukannan, which upheld the peak credit method for addition of undisclosed income, and the ITAT Chennai's order in the case of S. Kulanthaian, who is a relative of the assessee. The ITAT found no infirmity in the CIT(A)'s order and dismissed the Revenue's appeal.
The case pertains to the addition of undisclosed income u/s 69A of the Income Tax Act, wherein the peak credit method was applied. The Commissioner of Income Tax (Appeals) [CIT(A)] was satisfied with the assessee's business activities and cash collections deposited in bank accounts. The CIT(A) reproduced the details of the peak credit, considering opening balances in bank accounts, cash, advances, income from money lending business, and drawings. The CIT(A) determined the unexplained amount after deducting the net fund available from the peak credit. The CIT(A) relied on the decision of the Madras High Court in the case of PCIT v. S. Anbukannan, which upheld the peak credit method for addition of undisclosed income, and the ITAT Chennai's order in the case of S. Kulanthaian, who is a relative of the assessee. The ITAT found no infirmity in the CIT(A)'s order and dismissed the Revenue's appeal.
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