Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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...
ITAT upheld the CIT(A)'s order with key findings: (1) Electronic evidence seized during search was admissible under Section 65B of Indian Evidence Act, (2) Cash receipts from property sales would be taxed only on profit element estimated at 12.5%, (3) For eight plots, matter was remanded to AO for reference to DVO under Section 43CA, (4) Unaccounted scrap sales addition of 20% was confirmed, (5) Bogus steel purchase addition limited to 17% profit element, (6) Salary disallowance to an employee was deleted due to lack of corroborative evidence, and (7) Disallowance under Sections 40A(3) and 37 was rejected as no substantive evidence supported the addition. Overall, most additions were either deleted or substantially reduced.
ITAT upheld the CIT(A)'s order with key findings: (1) Electronic evidence seized during search was admissible under Section 65B of Indian Evidence Act, (2) Cash receipts from property sales would be taxed only on profit element estimated at 12.5%, (3) For eight plots, matter was remanded to AO for reference to DVO under Section 43CA, (4) Unaccounted scrap sales addition of 20% was confirmed, (5) Bogus steel purchase addition limited to 17% profit element, (6) Salary disallowance to an employee was deleted due to lack of corroborative evidence, and (7) Disallowance under Sections 40A(3) and 37 was rejected as no substantive evidence supported the addition. Overall, most additions were either deleted or substantially reduced.
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