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Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
ITAT upheld assessment beyond limitation period under s.153A as search evidence revealed undisclosed income exceeding Rs. 50 lakhs covering 7th to 10th assessment years. Documents found during search containing cheque transactions were not considered "dumb documents." Addition under s.69A sustained for unexplained Farm Account transactions in AY 2011-12. Cash found during search treated as business income rather than income from other sources, making s.115BBE inapplicable. Peak credit method accepted for s.68 additions regarding running account transactions. Blank uncashed cheques found during search not considered as income without evidence of completed transactions. Cash seized during search allowed to be adjusted against tax demand from assessment completion date, with s.234B interest recalculation directed.
ITAT upheld assessment beyond limitation period under s.153A as search evidence revealed undisclosed income exceeding Rs. 50 lakhs covering 7th to 10th assessment years. Documents found during search containing cheque transactions were not considered "dumb documents." Addition under s.69A sustained for unexplained Farm Account transactions in AY 2011-12. Cash found during search treated as business income rather than income from other sources, making s.115BBE inapplicable. Peak credit method accepted for s.68 additions regarding running account transactions. Blank uncashed cheques found during search not considered as income without evidence of completed transactions. Cash seized during search allowed to be adjusted against tax demand from assessment completion date, with s.234B interest recalculation directed.
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