Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
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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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