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Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
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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