Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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...
ITAT upheld the addition of unexplained investment, holding that the assessee (anonymized) failed to substantiate the source of funds for acquisition of immovable property for A.Y. 2016-17. The Tribunal found the unregistered agreement to sell inconsistent with bank evidence, noting purported receipt of consideration at the agreement date conflicted with actual cheque payments in July 2015, undermining documentary credibility. Further, the existence of an earlier joint development agreement and a supplementary agreement demarcating shares meant the developer lacked a definite sellable area before April 2012, rendering alleged payments prior to that date unverifiable. Consequently the assessee's claim was rejected and the assessment sustained against the assessee.
ITAT upheld the addition of unexplained investment, holding that the assessee (anonymized) failed to substantiate the source of funds for acquisition of immovable property for A.Y. 2016-17. The Tribunal found the unregistered agreement to sell inconsistent with bank evidence, noting purported receipt of consideration at the agreement date conflicted with actual cheque payments in July 2015, undermining documentary credibility. Further, the existence of an earlier joint development agreement and a supplementary agreement demarcating shares meant the developer lacked a definite sellable area before April 2012, rendering alleged payments prior to that date unverifiable. Consequently the assessee's claim was rejected and the assessment sustained against the assessee.
Note: It is a system-generated summary and is for quick reference only.