Employee stock-shortage penalties do not constitute consideration for services, preventing GST collection under Schedule II in employment relationship...
Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
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ITAT upheld the order of CIT(A) and dismissed Revenue's appeals, rejecting additions under s.68 and s.69C. The Tribunal found the assessee had furnished corroborative documentary evidence - ledger extracts, sales register, invoices, bank statements, e-way bills, transport details and VAT returns - demonstrating genuine sales recorded in books. The AO's additions rested solely on an isolated statement of a third party without independent corroborative or substantive material, and AO did not controvert the documentary evidence. Accordingly, the Tribunal held the AO's reliance on the investigation wing's finding that a purchaser was bogus was insufficient to sustain additions, and directed deletion of the impugned additions.
ITAT upheld the order of CIT(A) and dismissed Revenue's appeals, rejecting additions under s.68 and s.69C. The Tribunal found the assessee had furnished corroborative documentary evidence - ledger extracts, sales register, invoices, bank statements, e-way bills, transport details and VAT returns - demonstrating genuine sales recorded in books. The AO's additions rested solely on an isolated statement of a third party without independent corroborative or substantive material, and AO did not controvert the documentary evidence. Accordingly, the Tribunal held the AO's reliance on the investigation wing's finding that a purchaser was bogus was insufficient to sustain additions, and directed deletion of the impugned additions.
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