Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
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ITAT ruled in favor of assessee regarding unexplained money additions under s.69A for unsecured loan receipts. The tribunal found sufficient evidence proving loan disclosure in creditor's financial statements and proper reconciliation between rough and final balance sheets. Regarding additions under s.68 for partners' cash capital introduction, ITAT held that in completed/unabated assessments, additions cannot be made without incriminating material found during s.132 search. The tribunal confirmed assessee established partners' identity, transaction genuineness, and creditworthiness. CIT(A)'s finding that AO's additions were based merely on suspicion was upheld, as Revenue presented no contrary evidence. Both additions were deleted.
ITAT ruled in favor of assessee regarding unexplained money additions under s.69A for unsecured loan receipts. The tribunal found sufficient evidence proving loan disclosure in creditor's financial statements and proper reconciliation between rough and final balance sheets. Regarding additions under s.68 for partners' cash capital introduction, ITAT held that in completed/unabated assessments, additions cannot be made without incriminating material found during s.132 search. The tribunal confirmed assessee established partners' identity, transaction genuineness, and creditworthiness. CIT(A)'s finding that AO's additions were based merely on suspicion was upheld, as Revenue presented no contrary evidence. Both additions were deleted.
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