Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Customs Broker due diligence requires prescribed KYC, not detecting misdeclarations discoverable only through physical examination, defeating licence ...
E-filing system failure permits exclusion of affected time in insolvency appeals, preventing tribunal technology defects from defeating timely filings...
Pre-existing disputes over outcome-based professional fees can bar Section 9 insolvency proceedings where contractual entitlement requires investigati...
Corresponding scheduled offences preserve money-laundering jurisdiction despite repeal of the central corruption provision where conduct remains cover...
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ITAT ruled against the addition made under section 69 regarding unexplained investment in Oberoi Reality property. The assessee had provided complete documentation, banking channel evidence, and proper explanations for the property purchase made in 2010. The tribunal found that AO and DRP failed to specify valid grounds for rejecting the submitted evidence. Since the property was purchased in 2010 with major payments made that year, the addition in AY 2018-19 was inappropriate. The tribunal also emphasized that money brought to India by non-residents for investment purposes is not taxable when proper remittance evidence exists through banking channels. The appeal was allowed, and the addition was deleted.
ITAT ruled against the addition made under section 69 regarding unexplained investment in Oberoi Reality property. The assessee had provided complete documentation, banking channel evidence, and proper explanations for the property purchase made in 2010. The tribunal found that AO and DRP failed to specify valid grounds for rejecting the submitted evidence. Since the property was purchased in 2010 with major payments made that year, the addition in AY 2018-19 was inappropriate. The tribunal also emphasized that money brought to India by non-residents for investment purposes is not taxable when proper remittance evidence exists through banking channels. The appeal was allowed, and the addition was deleted.
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