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...
Assessments u/s 153A for AYs 2012-13, 2013-14 & 2014-15 were made based on statement of third party and material from search of third party, without any incriminating material found in assessee's case. As per SC ruling in Pr. CIT v. Abhisar Buildwell, such additions are impermissible u/s 153A. For abated AYs 2015-16 onwards, AO's powers aren't limited to incriminating material from search. However, where AO accepted assessee's explanation on source of funds based on documentary evidence in remand report, CIT(A) erred in brushing it aside without substantive reasons. Additions sustained by CIT(A) despite AO's findings in remand report are unsustainable.
Assessments u/s 153A for AYs 2012-13, 2013-14 & 2014-15 were made based on statement of third party and material from search of third party, without any incriminating material found in assessee's case. As per SC ruling in Pr. CIT v. Abhisar Buildwell, such additions are impermissible u/s 153A. For abated AYs 2015-16 onwards, AO's powers aren't limited to incriminating material from search. However, where AO accepted assessee's explanation on source of funds based on documentary evidence in remand report, CIT(A) erred in brushing it aside without substantive reasons. Additions sustained by CIT(A) despite AO's findings in remand report are unsustainable.
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