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...
Page of 4830
Press 'Enter' after typing page number.
161 to 180 of 96587 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
ITAT partially allowed taxpayer's appeal against additions made under Section 68 and Section 56(2)(viib) of Income Tax Act. Tribunal held that taxpayer adequately discharged burden of proof by providing confirmations, bank statements, and ITRs of share applicants. AO's rejection of creditworthiness solely based on investors' low-income levels without further inquiry was deemed legally untenable. Alternative addition under Section 56(2)(viib) was deleted as AO arbitrarily ignored DCF method. However, ITAT upheld disallowance of expenses under Section 57(iii) as taxpayer failed to demonstrate direct nexus between expenditure and income earned. Only statutory audit fees, postal and telephone charges were allowed as deductions.
ITAT partially allowed taxpayer's appeal against additions made under Section 68 and Section 56(2)(viib) of Income Tax Act. Tribunal held that taxpayer adequately discharged burden of proof by providing confirmations, bank statements, and ITRs of share applicants. AO's rejection of creditworthiness solely based on investors' low-income levels without further inquiry was deemed legally untenable. Alternative addition under Section 56(2)(viib) was deleted as AO arbitrarily ignored DCF method. However, ITAT upheld disallowance of expenses under Section 57(iii) as taxpayer failed to demonstrate direct nexus between expenditure and income earned. Only statutory audit fees, postal and telephone charges were allowed as deductions.
Note: It is a system-generated summary and is for quick reference only.