Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
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...
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Addition to assessee's income by enhancing closing stock value made by Assessing Officer (AO) u/s 143(3) was based solely on statement recorded during survey without any incriminating material. As per S Kader Khan Sons [2007 (7) TMI 182 - MADRAS HIGH COURT], statement recorded u/s 133A has no evidentiary value, and addition cannot be made based on such admission during survey. AO relied on gross profit rate declared during survey, but CIT(A) noted AO did not provide basis for adopting 17.43% rate instead of overall 13.08%. AO cannot make additions based on surmises and conjectures without rejecting books of account. CIT(A) examined consistent gross profit rates over previous years and deleted the addition. AO did not disallow purchases but enhanced closing stock, potentially affecting opening stock in subsequent year. Revenue's appeal against CIT(A) order was dismissed.
Addition to assessee's income by enhancing closing stock value made by Assessing Officer (AO) u/s 143(3) was based solely on statement recorded during survey without any incriminating material. As per S Kader Khan Sons [2007 (7) TMI 182 - MADRAS HIGH COURT], statement recorded u/s 133A has no evidentiary value, and addition cannot be made based on such admission during survey. AO relied on gross profit rate declared during survey, but CIT(A) noted AO did not provide basis for adopting 17.43% rate instead of overall 13.08%. AO cannot make additions based on surmises and conjectures without rejecting books of account. CIT(A) examined consistent gross profit rates over previous years and deleted the addition. AO did not disallow purchases but enhanced closing stock, potentially affecting opening stock in subsequent year. Revenue's appeal against CIT(A) order was dismissed.
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