Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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...
ITAT addressed three key issues in this tax appeal. The tribunal upheld the addition of undisclosed income based on electronic evidence from a seized pen drive, as proper certification under Section 65B(4) of Indian Evidence Act was obtained. Regarding unaccounted cash receipts, ITAT modified CIT(A)'s approach of applying 85% blanket rate, directing reassessment based on the assessee's declared net profit rates for respective years. On R&D deductions under Section 35(2AB), the tribunal confirmed that post July 2016, deductions must align with DSIR quantification, except for AY 2016-17 where full revenue expenditure deduction was allowed. The tribunal also upheld CIT(A)'s deletion of Section 69C additions after verifying opening cash balances from seized documents.
ITAT addressed three key issues in this tax appeal. The tribunal upheld the addition of undisclosed income based on electronic evidence from a seized pen drive, as proper certification under Section 65B(4) of Indian Evidence Act was obtained. Regarding unaccounted cash receipts, ITAT modified CIT(A)'s approach of applying 85% blanket rate, directing reassessment based on the assessee's declared net profit rates for respective years. On R&D deductions under Section 35(2AB), the tribunal confirmed that post July 2016, deductions must align with DSIR quantification, except for AY 2016-17 where full revenue expenditure deduction was allowed. The tribunal also upheld CIT(A)'s deletion of Section 69C additions after verifying opening cash balances from seized documents.
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