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Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
ITAT dismissed Revenue's appeal regarding unexplained expenditure under section 69C. The Tribunal found that the Assessing Officer (AO) erroneously made additions based on unsubstantiated handwritten loose documents without meaningful inquiry. The seized documents lacked corroboration, contained arithmetic mistakes, and did not align with shareholders' records. The Tribunal emphasized that loose sheets are inadmissible without additional evidence under the Indian Evidence Act. The Fair Market Value calculation was deemed appropriate, considering factors like intellectual capital and future profit potential. Ultimately, the appeal was rejected, with the Tribunal concluding that the additions made during the search action were not sacrosanct or conclusive.
ITAT dismissed Revenue's appeal regarding unexplained expenditure under section 69C. The Tribunal found that the Assessing Officer (AO) erroneously made additions based on unsubstantiated handwritten loose documents without meaningful inquiry. The seized documents lacked corroboration, contained arithmetic mistakes, and did not align with shareholders' records. The Tribunal emphasized that loose sheets are inadmissible without additional evidence under the Indian Evidence Act. The Fair Market Value calculation was deemed appropriate, considering factors like intellectual capital and future profit potential. Ultimately, the appeal was rejected, with the Tribunal concluding that the additions made during the search action were not sacrosanct or conclusive.
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