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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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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