Assessing Officer jurisdiction after statutory transfer invalidates reassessment notices issued by transferor officers and nullifies resulting proceed...
Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
Fraud classification show-cause notices founded on inconclusive forensic audit material cannot sustain action, permitting fresh proceedings on conclus...
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Assessee, a distributor of SIM cards and vouchers for Vodafone Mobile Services Limited, earned commission on sales to retail shops. Cash deposits were considered business receipts reinvested in purchasing new SIM cards and vouchers, with consistent fund rotation reflected in bank statements provided to authorities. CIT(A) erred in treating entire sales as income without considering business turnover and payments to Vodafone. ITAT directed AO to calculate estimated profit at 1% on transactions, quashing addition u/s 69A as source of deposits was established. Interest u/ss 234A, 234B, and 234C was denied due to income below taxable limit. ITAT emphasized careful handling of such cases by AOs as adjudicators and investigators. Assessee's appeal was allowed, providing relief from addition of Rs. 1,51,77,749.
Assessee, a distributor of SIM cards and vouchers for Vodafone Mobile Services Limited, earned commission on sales to retail shops. Cash deposits were considered business receipts reinvested in purchasing new SIM cards and vouchers, with consistent fund rotation reflected in bank statements provided to authorities. CIT(A) erred in treating entire sales as income without considering business turnover and payments to Vodafone. ITAT directed AO to calculate estimated profit at 1% on transactions, quashing addition u/s 69A as source of deposits was established. Interest u/ss 234A, 234B, and 234C was denied due to income below taxable limit. ITAT emphasized careful handling of such cases by AOs as adjudicators and investigators. Assessee's appeal was allowed, providing relief from addition of Rs. 1,51,77,749.
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