Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
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Regarding the additions made u/s 153A, the ITAT held that since no incriminating material was referred to by the Assessing Officer (AO) during the search, no additions could be made in a completed assessment as per the Supreme Court's decision in Abhisar Buildwell Pvt. Ltd. Secondly, concerning the addition of bogus purchases, the ITAT observed that the purchases were accounted for in the regular books, and the source of payments was duly explained. Hence, the provisions of Section 69C were not applicable. Thirdly, regarding the addition u/s 69A, the ITAT upheld the Commissioner of Income Tax (Appeals) [CIT(A)]'s deletion of the addition, considering the assessee's retracted undisclosed income figure backed by credible evidence and the presumption u/ss 132(4A) and 292C.
Regarding the additions made u/s 153A, the ITAT held that since no incriminating material was referred to by the Assessing Officer (AO) during the search, no additions could be made in a completed assessment as per the Supreme Court's decision in Abhisar Buildwell Pvt. Ltd. Secondly, concerning the addition of bogus purchases, the ITAT observed that the purchases were accounted for in the regular books, and the source of payments was duly explained. Hence, the provisions of Section 69C were not applicable. Thirdly, regarding the addition u/s 69A, the ITAT upheld the Commissioner of Income Tax (Appeals) [CIT(A)]'s deletion of the addition, considering the assessee's retracted undisclosed income figure backed by credible evidence and the presumption u/ss 132(4A) and 292C.
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