Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes...
Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
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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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