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Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Non-resident assessee, a regular income tax filer, was subject to best judgment assessment u/s 144 for unexplained investment in mutual funds u/s 69. Assessee submitted additional evidence u/r 46A, which the Assessing Officer and CIT(A) failed to consider properly. ITAT observed assessee is an NRI with income sourced outside India, and the investment was traceable from bank statements. CIT(A) rightly deleted the addition on mutual fund investment and long-term capital gains on sale of equity-oriented mutual funds, being exempt u/s 10(38). ITAT upheld CIT(A)'s order, finding no reason to interfere given the evidence on record.
Non-resident assessee, a regular income tax filer, was subject to best judgment assessment u/s 144 for unexplained investment in mutual funds u/s 69. Assessee submitted additional evidence u/r 46A, which the Assessing Officer and CIT(A) failed to consider properly. ITAT observed assessee is an NRI with income sourced outside India, and the investment was traceable from bank statements. CIT(A) rightly deleted the addition on mutual fund investment and long-term capital gains on sale of equity-oriented mutual funds, being exempt u/s 10(38). ITAT upheld CIT(A)'s order, finding no reason to interfere given the evidence on record.
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