Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
The sales declared by the assessee were treated as bogus, leading to an addition u/s 69A. However, the CIT(A) found that the AO accepted the purchases, inventory, and net profit declared by the assessee. The AO's presumption that the assessee rerouted their own funds was not backed by material evidence. Consequently, the addition was dismissed. Regarding reassessment proceedings, the approval granted u/s 151 was invalid as it was granted for another person's assessment, with the reason merely recorded as 'yes', indicating a mechanical approval. Therefore, the initiation of proceedings itself was held as bad in law, and the assessment made in the assessee's case was set aside. The assessee's appeal was allowed.
The sales declared by the assessee were treated as bogus, leading to an addition u/s 69A. However, the CIT(A) found that the AO accepted the purchases, inventory, and net profit declared by the assessee. The AO's presumption that the assessee rerouted their own funds was not backed by material evidence. Consequently, the addition was dismissed. Regarding reassessment proceedings, the approval granted u/s 151 was invalid as it was granted for another person's assessment, with the reason merely recorded as 'yes', indicating a mechanical approval. Therefore, the initiation of proceedings itself was held as bad in law, and the assessment made in the assessee's case was set aside. The assessee's appeal was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
