Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
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...
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ITAT dismissed the Revenue's appeal and upheld in toto the order of the CIT(A) deleting the addition of Rs. 15.80 crore towards alleged bogus wage expenditure for A.Y. 2022-23 in the case of Assessee Co. ITAT held that the AO's reliance on cash scroll notings such as "MD Personal" was unsupported by any corroborative evidence, cash trail, or proof of personal use by the Managing Director, and that such private notings cannot, by themselves, constitute conclusive evidence of non-genuine expenditure. As the AO had not rejected the books under s.145, and the assessee's profit ratio was consistent with past years, the impugned disallowance was found arbitrary and unsustainable. All grounds raised by the Revenue were rejected.
ITAT dismissed the Revenue's appeal and upheld in toto the order of the CIT(A) deleting the addition of Rs. 15.80 crore towards alleged bogus wage expenditure for A.Y. 2022-23 in the case of Assessee Co. ITAT held that the AO's reliance on cash scroll notings such as "MD Personal" was unsupported by any corroborative evidence, cash trail, or proof of personal use by the Managing Director, and that such private notings cannot, by themselves, constitute conclusive evidence of non-genuine expenditure. As the AO had not rejected the books under s.145, and the assessee's profit ratio was consistent with past years, the impugned disallowance was found arbitrary and unsustainable. All grounds raised by the Revenue were rejected.
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