Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
The ITAT held that in cases of accommodation entries, additions should be limited to the profit element embedded in the bogus transactions rather than the entire transaction value. The Tribunal found the Assessing Officer's addition of 10% on total sales and purchases unjustified, as it was made without proper investigation and solely based on the Verification Unit's report, which wasn't provided to the assessee. Following precedent from the Surat Bench in similar cases, the ITAT restricted the addition to 6% of the purchase amount (3,11,75,748) and 0.5% of sales amount (6,20,94,701), acknowledging that only real income after expense set-off can be taxed, not the substantial part of transactions.
The ITAT held that in cases of accommodation entries, additions should be limited to the profit element embedded in the bogus transactions rather than the entire transaction value. The Tribunal found the Assessing Officer's addition of 10% on total sales and purchases unjustified, as it was made without proper investigation and solely based on the Verification Unit's report, which wasn't provided to the assessee. Following precedent from the Surat Bench in similar cases, the ITAT restricted the addition to 6% of the purchase amount (3,11,75,748) and 0.5% of sales amount (6,20,94,701), acknowledging that only real income after expense set-off can be taxed, not the substantial part of transactions.
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