Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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Assessee engaged in business of commission agent (Aadatia) for agricultural products. AO made addition u/s 68 treating entire cash deposits in bank account as unexplained, alleging undisclosed trading activity. CIT(A) deleted addition after considering cash books, ledgers, bank statements of three proprietorship concerns, observing cash deposits duly recorded relating to consignment sales over Rs. 17 crores, part received in cash. ITAT upheld CIT(A)'s decision, noting AO failed to rebut assessee's explanation that cash deposits represented sale proceeds received on farmers' behalf, incidental to commission income. AO could have cross-verified from Mandi Samiti records but didn't. Only real income taxable, AO erred by taxing receipts instead of commission income. CIT(A) also deleted 25% disallowance of expenses made by AO, as assessee substantiated salary payments through evidence like employee confirmations, volume of Rs. 17 crore business necessitating manpower. ITAT found no infirmity in CIT(A)'s well-reasoned order based on evidence. Revenue's appeal dismissed.
Assessee engaged in business of commission agent (Aadatia) for agricultural products. AO made addition u/s 68 treating entire cash deposits in bank account as unexplained, alleging undisclosed trading activity. CIT(A) deleted addition after considering cash books, ledgers, bank statements of three proprietorship concerns, observing cash deposits duly recorded relating to consignment sales over Rs. 17 crores, part received in cash. ITAT upheld CIT(A)'s decision, noting AO failed to rebut assessee's explanation that cash deposits represented sale proceeds received on farmers' behalf, incidental to commission income. AO could have cross-verified from Mandi Samiti records but didn't. Only real income taxable, AO erred by taxing receipts instead of commission income. CIT(A) also deleted 25% disallowance of expenses made by AO, as assessee substantiated salary payments through evidence like employee confirmations, volume of Rs. 17 crore business necessitating manpower. ITAT found no infirmity in CIT(A)'s well-reasoned order based on evidence. Revenue's appeal dismissed.
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