Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
Customs exemptions cover photovoltaic assembly machinery and PVF backsheets, while fully declared cleared imports may avoid confiscation and penalties...
Specific tariff classification for LCD devices overrides treatment as electricity-meter parts, defeating differential duty, extended limitation, and p...
Stayed disciplinary punishment does not establish unfitness for insolvency professional registration; reconsideration must disregard mere pendency of ...
Indirect corporate control can create related-party status, excluding financial creditors from Committee of Creditors representation, participation an...
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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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