Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
ITAT addressed multiple taxation issues involving unexplained income and profit calculations. The tribunal found that when entire contract receipts were treated as unexplained, no further profit addition was justified. The CIT(A)'s order was set aside due to procedural irregularities in admitting additional evidence without providing the AO an opportunity to examine such evidence, as mandated under Rule 46A(3) of IT Rules. The tribunal upheld the 10% profit rate calculation, noting it was more reasonable than the AO's unsubstantiated 20% rate. The matter was remanded to the first appellate authority for reconsideration, ensuring procedural compliance and fair assessment of the taxpayer's income.
ITAT addressed multiple taxation issues involving unexplained income and profit calculations. The tribunal found that when entire contract receipts were treated as unexplained, no further profit addition was justified. The CIT(A)'s order was set aside due to procedural irregularities in admitting additional evidence without providing the AO an opportunity to examine such evidence, as mandated under Rule 46A(3) of IT Rules. The tribunal upheld the 10% profit rate calculation, noting it was more reasonable than the AO's unsubstantiated 20% rate. The matter was remanded to the first appellate authority for reconsideration, ensuring procedural compliance and fair assessment of the taxpayer's income.
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TaxTMI 
TaxTMI 
