Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
Jurisdictional issue regarding notice u/s 143(2) was addressed, with ITAT holding that the initial notice by ACIT, Circle-5(1), Delhi was within time, and subsequent transfer to jurisdictional AO did not invalidate proceedings. Regarding addition u/ss 68/69C, ITAT held CIT(A) erred in making addition u/s 69C without issuing show cause notice as mandated u/s 251. Books of account were accepted by AO, who did not reject them or make efforts to verify sundry creditors. Additions u/s 68 cannot be made when sales, purchases, and gross profit were disclosed and accepted. CIT(A)'s addition u/s 69C on grounds of non-banking channel purchases was incorrect when sales were accepted and gross profit rate increased. ITAT deleted CIT(A)'s addition u/s 69C, allowing assessee's appeal.
Jurisdictional issue regarding notice u/s 143(2) was addressed, with ITAT holding that the initial notice by ACIT, Circle-5(1), Delhi was within time, and subsequent transfer to jurisdictional AO did not invalidate proceedings. Regarding addition u/ss 68/69C, ITAT held CIT(A) erred in making addition u/s 69C without issuing show cause notice as mandated u/s 251. Books of account were accepted by AO, who did not reject them or make efforts to verify sundry creditors. Additions u/s 68 cannot be made when sales, purchases, and gross profit were disclosed and accepted. CIT(A)'s addition u/s 69C on grounds of non-banking channel purchases was incorrect when sales were accepted and gross profit rate increased. ITAT deleted CIT(A)'s addition u/s 69C, allowing assessee's appeal.
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