Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability ...
Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
Section 80P deduction for co-operative societies remains available despite nominal members and housing society status, with limited interest income tr...
The ITAT set aside the disallowance of freight charges, holding that mere suspicion without proof cannot justify rejecting expenses substantiated by audited accounts and vouchers. The disallowance under section 14A was deleted due to the AO's failure to record proper satisfaction before making additions. Additions based solely on Form 26AS mismatch were reversed as the assessee declared the amount in a subsequent year, preventing double taxation. The issue of carry forward losses was remitted to the AO for verification in accordance with law, with a direction to afford the assessee an opportunity of hearing. Disallowance of interest expenditure was also reversed, as the assessee had interest-free funds evidenced by loans and inventory financing, precluding blanket disallowance of finance costs. The appeal was allowed in part, with remand and deletion of certain additions.
The ITAT set aside the disallowance of freight charges, holding that mere suspicion without proof cannot justify rejecting expenses substantiated by audited accounts and vouchers. The disallowance under section 14A was deleted due to the AO's failure to record proper satisfaction before making additions. Additions based solely on Form 26AS mismatch were reversed as the assessee declared the amount in a subsequent year, preventing double taxation. The issue of carry forward losses was remitted to the AO for verification in accordance with law, with a direction to afford the assessee an opportunity of hearing. Disallowance of interest expenditure was also reversed, as the assessee had interest-free funds evidenced by loans and inventory financing, precluding blanket disallowance of finance costs. The appeal was allowed in part, with remand and deletion of certain additions.
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