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...
Bogus commodity loss transaction identified as mere accommodation entry facilitated through complex fund routing. Revenue's investigation revealed modus operandi of transactions between parties, corroborated by money trail and admission by directors, establishing impugned transactions as accommodation entries for tax benefit. Burden of proof shifted to assessee to controvert findings, which was not discharged satisfactorily. Transaction treated as bogus, reducing cost of land acquisition. Unexplained credit addition deleted as source of funds established as genuine. Interest disallowance on loans reversed as source held genuine. Disallowance u/s 14A rightly deleted in absence of exempt income. Appellate Tribunal upheld Revenue's findings and assessee's contentions rejected.
Bogus commodity loss transaction identified as mere accommodation entry facilitated through complex fund routing. Revenue's investigation revealed modus operandi of transactions between parties, corroborated by money trail and admission by directors, establishing impugned transactions as accommodation entries for tax benefit. Burden of proof shifted to assessee to controvert findings, which was not discharged satisfactorily. Transaction treated as bogus, reducing cost of land acquisition. Unexplained credit addition deleted as source of funds established as genuine. Interest disallowance on loans reversed as source held genuine. Disallowance u/s 14A rightly deleted in absence of exempt income. Appellate Tribunal upheld Revenue's findings and assessee's contentions rejected.
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