Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
ITAT held that the revisionary proceedings u/s 263 were valid and the assessee cannot challenge the order since it had attained finality. In the substantive matter concerning unexplained cash credit u/s 68 for share capital and share premium from 18 private limited applicants, the tribunal found that the assessee successfully established the identity, genuineness, and creditworthiness of share applicants through their tax assessments, financial statements, and ROC scrutiny. Consequently, the tribunal deleted the addition u/s 68, set aside the CIT(A)'s order, and allowed the assessee's grounds 1-5, concluding no addition was warranted based on the comprehensive documentation and verification of investment sources.
ITAT held that the revisionary proceedings u/s 263 were valid and the assessee cannot challenge the order since it had attained finality. In the substantive matter concerning unexplained cash credit u/s 68 for share capital and share premium from 18 private limited applicants, the tribunal found that the assessee successfully established the identity, genuineness, and creditworthiness of share applicants through their tax assessments, financial statements, and ROC scrutiny. Consequently, the tribunal deleted the addition u/s 68, set aside the CIT(A)'s order, and allowed the assessee's grounds 1-5, concluding no addition was warranted based on the comprehensive documentation and verification of investment sources.
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