Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
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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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