Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
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...
The ITAT held that the addition of unsecured loan as unexplained income under section 69A read with section 115BBE was not sustainable without proper examination of relevant evidence. The Tribunal noted that additional evidence submitted by the assessee, including an MOU and an affidavit, was not considered by the AO, who relied solely on seized documents. Since the additional evidence could not have been filed earlier as it arose post the lower authorities' orders, the ITAT allowed the assessee's appeal for statistical purposes and remanded the matter to the AO for fresh adjudication after considering all relevant evidence, including the affidavit of Sumitradevi Chaudhary.
The ITAT held that the addition of unsecured loan as unexplained income under section 69A read with section 115BBE was not sustainable without proper examination of relevant evidence. The Tribunal noted that additional evidence submitted by the assessee, including an MOU and an affidavit, was not considered by the AO, who relied solely on seized documents. Since the additional evidence could not have been filed earlier as it arose post the lower authorities' orders, the ITAT allowed the assessee's appeal for statistical purposes and remanded the matter to the AO for fresh adjudication after considering all relevant evidence, including the affidavit of Sumitradevi Chaudhary.
Note: It is a system-generated summary and is for quick reference only.