Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
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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