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...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
