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ITAT upheld CIT(A)'s findings, rejecting revenue's contentions regarding disallowances and additions. The tribunal confirmed the assessee's claims on salary payments, professional charges, and transactions with specified entities, emphasizing principle of consistency and tax neutrality. Key observations included: payments were duly taxed, services were legitimate, and no material evidence supported revenue's estimations. The tribunal declined to interfere with CIT(A)'s nuanced analysis, partially modifying the order by reversing 20% estimated additions to specified concerns. Foreign investments and remittances were also validated, with the assessee's compliance with RBI and tax regulations being recognized.
ITAT upheld CIT(A)'s findings, rejecting revenue's contentions regarding disallowances and additions. The tribunal confirmed the assessee's claims on salary payments, professional charges, and transactions with specified entities, emphasizing principle of consistency and tax neutrality. Key observations included: payments were duly taxed, services were legitimate, and no material evidence supported revenue's estimations. The tribunal declined to interfere with CIT(A)'s nuanced analysis, partially modifying the order by reversing 20% estimated additions to specified concerns. Foreign investments and remittances were also validated, with the assessee's compliance with RBI and tax regulations being recognized.
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