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...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
In the absence of incriminating material found during the search u/s 153A, no addition can be made for the assessment year 2012-13, except supported by incriminating documents. This view finds support from the Supreme Court's judgment in PCIT vs. Abhisar Buildwell P. Ltd., wherein it was held that no addition can be made for completed assessments without incriminating material. Further, the Rajasthan High Court's decision in PCIT vs. M/s. Esspal International P. Ltd. stated that merely based on a retracted statement, no addition can be sustained. Consequently, the addition was directed to be deleted, deciding in favor of the assessee.
In the absence of incriminating material found during the search u/s 153A, no addition can be made for the assessment year 2012-13, except supported by incriminating documents. This view finds support from the Supreme Court's judgment in PCIT vs. Abhisar Buildwell P. Ltd., wherein it was held that no addition can be made for completed assessments without incriminating material. Further, the Rajasthan High Court's decision in PCIT vs. M/s. Esspal International P. Ltd. stated that merely based on a retracted statement, no addition can be sustained. Consequently, the addition was directed to be deleted, deciding in favor of the assessee.
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