Transaction value cannot be rejected solely on non-statutory valuation guidelines without corroborative evidence supporting reassessment of final cust...
Cross-examination rights and corroborated evidence limit customs penalties for misdeclaration in genuine import transactions involving documented clea...
Tariff classification of vehicle gear components follows the specific gearing entry, displacing motor-vehicle parts classification and related liabili...
Necessary-party requirements limit impleadment of independent entities, while deferred consideration does not create an appealable adverse determinati...
Food supplement classification requires common parlance and authoritative tests, preventing treatment as proprietary Ayurvedic medicines without suppo...
The ITAT upheld the CIT(A)'s deletion of additions under section 68 relating to unsecured loans, finding the assessee satisfactorily proved the identity and creditworthiness of lenders and genuineness of transactions, supported by banking channel evidence and legal precedents. The tribunal confirmed that denial of cross-examination rendered the AO's additions unsustainable. Consequently, disallowance of interest on such loans and alleged commission payments were also deleted. The reassessment order under section 147 was quashed as the AO exceeded jurisdiction by making additions beyond the reasons recorded. Additions based on uncorroborated WhatsApp chats were deleted, adhering to principles against relying on non-speaking documents without corroborative evidence. The CIT(A)'s confirmation of disallowance of education and health cess expenses under section 40(a)(ii) and disallowance of delayed PF and ESI contributions under section 36(1)(va) was affirmed, following Supreme Court rulings. All revenue appeals were dismissed.
The ITAT upheld the CIT(A)'s deletion of additions under section 68 relating to unsecured loans, finding the assessee satisfactorily proved the identity and creditworthiness of lenders and genuineness of transactions, supported by banking channel evidence and legal precedents. The tribunal confirmed that denial of cross-examination rendered the AO's additions unsustainable. Consequently, disallowance of interest on such loans and alleged commission payments were also deleted. The reassessment order under section 147 was quashed as the AO exceeded jurisdiction by making additions beyond the reasons recorded. Additions based on uncorroborated WhatsApp chats were deleted, adhering to principles against relying on non-speaking documents without corroborative evidence. The CIT(A)'s confirmation of disallowance of education and health cess expenses under section 40(a)(ii) and disallowance of delayed PF and ESI contributions under section 36(1)(va) was affirmed, following Supreme Court rulings. All revenue appeals were dismissed.
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