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...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
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ITAT dismissed the Revenue's appeal challenging AO's additions under sections 68/69/69A treating certain cash deposits as unexplained and applying section 115BBE at 60%, concluding the consequential tax effect is insufficient to sustain the appeal. The Tribunal held that the enhanced levy under section 115BBE applies only to transactions occurring on or after 01.04.2017, and therefore the AO's higher-tax computation was not tenable. Applying the CBDT Circular No. 09 of 2024 on low tax effect, the appeal was found to lack sufficient revenue consequence and was dismissed, leaving the assessment adjustments (as limited by applicable temporal scope and normal provisions) unupheld in favour of the Revenue.
ITAT dismissed the Revenue's appeal challenging AO's additions under sections 68/69/69A treating certain cash deposits as unexplained and applying section 115BBE at 60%, concluding the consequential tax effect is insufficient to sustain the appeal. The Tribunal held that the enhanced levy under section 115BBE applies only to transactions occurring on or after 01.04.2017, and therefore the AO's higher-tax computation was not tenable. Applying the CBDT Circular No. 09 of 2024 on low tax effect, the appeal was found to lack sufficient revenue consequence and was dismissed, leaving the assessment adjustments (as limited by applicable temporal scope and normal provisions) unupheld in favour of the Revenue.
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