Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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The ITAT upheld the CIT(A)'s deletion of additions under section 68 concerning unexplained share capital and share premium credits, finding the assessee successfully demonstrated these were earlier credited funds transferred via journal entries among related parties, with no fresh funds introduced during the relevant year. Consequently, the revenue's appeal on this ground was dismissed. However, regarding advances shown under other liabilities, the CIT(A) accepted fresh evidence without remanding the matter to the AO for verification of identity, genuineness, and creditworthiness of the parties, violating procedural requirements. The ITAT agreed with the revenue that the issue required reconsideration and partly allowed the appeal for statistical purposes, mandating further examination of the advances' legitimacy.
The ITAT upheld the CIT(A)'s deletion of additions under section 68 concerning unexplained share capital and share premium credits, finding the assessee successfully demonstrated these were earlier credited funds transferred via journal entries among related parties, with no fresh funds introduced during the relevant year. Consequently, the revenue's appeal on this ground was dismissed. However, regarding advances shown under other liabilities, the CIT(A) accepted fresh evidence without remanding the matter to the AO for verification of identity, genuineness, and creditworthiness of the parties, violating procedural requirements. The ITAT agreed with the revenue that the issue required reconsideration and partly allowed the appeal for statistical purposes, mandating further examination of the advances' legitimacy.
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