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 reversed additions made under sections 41(1) and 69 of Income Tax Act. Regarding s.41(1), outstanding trade payables to supplier since FY 2011-12 for defective materials were consistently shown in books, with no cessation of liability established. Following precedent, mere non-payment without remission does not satisfy s.41(1) requirements. Previous ITAT ruling for AY 2012-13 had already examined creditor authenticity. On s.69 addition, demand draft for land registration was properly recorded as fixed asset in FY 2014-15 books, negating unexplained investment presumption. Revenue's contradictory position in subsequent year deemed improper. Appeal allowed with both additions deleted.
ITAT reversed additions made under sections 41(1) and 69 of Income Tax Act. Regarding s.41(1), outstanding trade payables to supplier since FY 2011-12 for defective materials were consistently shown in books, with no cessation of liability established. Following precedent, mere non-payment without remission does not satisfy s.41(1) requirements. Previous ITAT ruling for AY 2012-13 had already examined creditor authenticity. On s.69 addition, demand draft for land registration was properly recorded as fixed asset in FY 2014-15 books, negating unexplained investment presumption. Revenue's contradictory position in subsequent year deemed improper. Appeal allowed with both additions deleted.
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