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...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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The SC dismissed the SLP, upholding the HC's affirmance of the ITAT's factual conclusion that the AO's addition of alleged outstanding liabilities payable to two banks to the assessee's returned income was justified. The Court held the genuineness and existence of the claimed transactions were questions of fact, noting the absence of sufficient evidentiary material to demonstrate receipt (and subsequent return) of goods or to substantiate the asserted liabilities. No perversity or patent illegality in the concurrent findings of fact was found, and there was no basis to interfere with the impugned HC order sustaining the addition.
The SC dismissed the SLP, upholding the HC's affirmance of the ITAT's factual conclusion that the AO's addition of alleged outstanding liabilities payable to two banks to the assessee's returned income was justified. The Court held the genuineness and existence of the claimed transactions were questions of fact, noting the absence of sufficient evidentiary material to demonstrate receipt (and subsequent return) of goods or to substantiate the asserted liabilities. No perversity or patent illegality in the concurrent findings of fact was found, and there was no basis to interfere with the impugned HC order sustaining the addition.
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