Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
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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