Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
ITAT held that additions for alleged capital gains and unexplained cash under section 69A, founded solely on uncorroborated personal diary entries and retracted statements of employees/directors, lacked evidentiary foundation and were deleted. Reassessment proceedings initiated by the jurisdictional AO were declared void ab initio as jurisdiction had vested in the Faceless Assessing Officer under the notified scheme; consequently the section 148 notice was coram non judice. The assessment order was also vitiated for failure to generate/quote a valid pre-generated DIN, rendering it a nullity. The appellate enhancement sought by Revenue was held not maintainable for want of cogent material within the scope of matters before the AO/CIT(A).
ITAT held that additions for alleged capital gains and unexplained cash under section 69A, founded solely on uncorroborated personal diary entries and retracted statements of employees/directors, lacked evidentiary foundation and were deleted. Reassessment proceedings initiated by the jurisdictional AO were declared void ab initio as jurisdiction had vested in the Faceless Assessing Officer under the notified scheme; consequently the section 148 notice was coram non judice. The assessment order was also vitiated for failure to generate/quote a valid pre-generated DIN, rendering it a nullity. The appellate enhancement sought by Revenue was held not maintainable for want of cogent material within the scope of matters before the AO/CIT(A).
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