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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The ITAT dismissed Revenue's appeal regarding unsecured loans under s.68, upholding CIT(A)'s deletion of additions after verifying lenders' documentation and creditworthiness. The Tribunal noted that CIT(A) possesses co-terminus powers with the AO and had properly examined all evidence. Regarding cash found during search, the ITAT allowed the assessee's appeal, accepting that the seized cash belonged to the company where assessee worked as Finance Head, as corroborated by the company's books. The Tribunal rejected additions for alleged on-money payments for flat purchase, ruling that evidence from a third-party search couldn't be used in s.153A proceedings without initiating separate s.153C proceedings with proper satisfaction note. Interest under s.234A was confirmed as mandatory for late filing, while s.234C interest was limited to returned income only.
The ITAT dismissed Revenue's appeal regarding unsecured loans under s.68, upholding CIT(A)'s deletion of additions after verifying lenders' documentation and creditworthiness. The Tribunal noted that CIT(A) possesses co-terminus powers with the AO and had properly examined all evidence. Regarding cash found during search, the ITAT allowed the assessee's appeal, accepting that the seized cash belonged to the company where assessee worked as Finance Head, as corroborated by the company's books. The Tribunal rejected additions for alleged on-money payments for flat purchase, ruling that evidence from a third-party search couldn't be used in s.153A proceedings without initiating separate s.153C proceedings with proper satisfaction note. Interest under s.234A was confirmed as mandatory for late filing, while s.234C interest was limited to returned income only.
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