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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 CIT(A)'s decision restricting additions under section 153C search assessments. For unaccounted receipts, ITAT confirmed 20% profit margin on verifiable on-money receipts for AY 2015-16 only, deleting extrapolated additions for subsequent years lacking year-specific incriminating material. The tribunal emphasized that additions in non-abated assessments require incriminating documents relatable to specific assessment years. Regarding unaccounted land investment under section 69, ITAT deleted additions finding payments sourced from already-taxed unaccounted receipts, preventing double taxation. For alleged unaccounted cash expenditure under section 69C, ITAT upheld deletion as seized documents from third-party premises lacked nexus to assessee's business, with AO failing to establish connection through proper enquiry or corroboration.
ITAT upheld CIT(A)'s decision restricting additions under section 153C search assessments. For unaccounted receipts, ITAT confirmed 20% profit margin on verifiable on-money receipts for AY 2015-16 only, deleting extrapolated additions for subsequent years lacking year-specific incriminating material. The tribunal emphasized that additions in non-abated assessments require incriminating documents relatable to specific assessment years. Regarding unaccounted land investment under section 69, ITAT deleted additions finding payments sourced from already-taxed unaccounted receipts, preventing double taxation. For alleged unaccounted cash expenditure under section 69C, ITAT upheld deletion as seized documents from third-party premises lacked nexus to assessee's business, with AO failing to establish connection through proper enquiry or corroboration.
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