Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Nominee director protection shields independent financial-institution appointees from criminal liability where they lack involvement in deposit defaul...
The ITAT held that the approval under section 151 without a valid manual or digital signature is invalid, rendering the subsequent notice under section 148 void for lack of jurisdiction; thus, the reassessment order under section 143(3) read with section 147 was quashed. The issuance of notice under section 148 by a JAO was upheld as valid under the faceless regime. Income from sale of scrap was held to be business income, not unexplained cash under section 69A, and the estimated additions on this account were partly deleted, with the profit estimated using the PBT percentage from regular books. Out-of-books expenses disallowance under section 69C was deleted. Bogus salary and professional fees disallowance under section 37(1) was reversed. Certain estimated disallowances were sustained. Additions based on diary entries were largely disallowed due to inadequate proof of unexplained income. Business promotion expenses were fully allowed as wholly and exclusively incurred for business.
The ITAT held that the approval under section 151 without a valid manual or digital signature is invalid, rendering the subsequent notice under section 148 void for lack of jurisdiction; thus, the reassessment order under section 143(3) read with section 147 was quashed. The issuance of notice under section 148 by a JAO was upheld as valid under the faceless regime. Income from sale of scrap was held to be business income, not unexplained cash under section 69A, and the estimated additions on this account were partly deleted, with the profit estimated using the PBT percentage from regular books. Out-of-books expenses disallowance under section 69C was deleted. Bogus salary and professional fees disallowance under section 37(1) was reversed. Certain estimated disallowances were sustained. Additions based on diary entries were largely disallowed due to inadequate proof of unexplained income. Business promotion expenses were fully allowed as wholly and exclusively incurred for business.
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