Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
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The ITAT upheld the AO's disallowance under section 292C, finding no contemporaneous claim of expenses or liabilities during the survey and dismissing the assessee's Ground No.2; the addition stands. The Tribunal directed recalculation of allowable partners' remuneration under section 40(b) (Explanation 3) by computing book profit after adding back confirmed additions of Rs. 62,28,947 and adhoc disallowances of Rs. 15,620, and ordered the AO to allow the remuneration claim accordingly. The Bench held that income declared during survey is taxable as business income under section 28, hence section 115BBE, and provisions applicable to deemed unexplained credits are not attracted.
The ITAT upheld the AO's disallowance under section 292C, finding no contemporaneous claim of expenses or liabilities during the survey and dismissing the assessee's Ground No.2; the addition stands. The Tribunal directed recalculation of allowable partners' remuneration under section 40(b) (Explanation 3) by computing book profit after adding back confirmed additions of Rs. 62,28,947 and adhoc disallowances of Rs. 15,620, and ordered the AO to allow the remuneration claim accordingly. The Bench held that income declared during survey is taxable as business income under section 28, hence section 115BBE, and provisions applicable to deemed unexplained credits are not attracted.
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