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Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
ITAT held that no incriminating material was found during income tax search of the assessee on 2.1.2020 for a completed assessment year. Statutory documents like charge sheets in public domain cannot be considered incriminating evidence. Statements from three individuals were deemed bald and did not reveal undisclosed income. The approval under section 153D was granted mechanically without due application of mind, rendering the assessment void ab initio. Consequently, additions made by the Assessing Officer were deleted, and the assessment for Assessment Year 2011-12 was quashed based on the Supreme Court's ratio decidendi in Abhishar Buildwell case.
ITAT held that no incriminating material was found during income tax search of the assessee on 2.1.2020 for a completed assessment year. Statutory documents like charge sheets in public domain cannot be considered incriminating evidence. Statements from three individuals were deemed bald and did not reveal undisclosed income. The approval under section 153D was granted mechanically without due application of mind, rendering the assessment void ab initio. Consequently, additions made by the Assessing Officer were deleted, and the assessment for Assessment Year 2011-12 was quashed based on the Supreme Court's ratio decidendi in Abhishar Buildwell case.
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