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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ITAT dismissed Revenue's appeal and upheld the order of CIT(A) in toto. The Tribunal affirmed deletion of addition u/s 68 r/w s.115BBE on alleged unexplained sundry creditors, holding that only opening balances were involved and no fresh credit arose in the relevant previous year. Disallowance of GST expenditure was sustained as allowable business outgo, the liability having crystallized during the year when input tax credit had lapsed. On alleged bogus purchases, ITAT endorsed CIT(A)'s restriction of addition to a nominal gross profit rate, as books were audited, not rejected, and sales and stock records were accepted. Deletion of addition on alleged difference in purchases was also confirmed, the AO having miscompared net and gross figures.
ITAT dismissed Revenue's appeal and upheld the order of CIT(A) in toto. The Tribunal affirmed deletion of addition u/s 68 r/w s.115BBE on alleged unexplained sundry creditors, holding that only opening balances were involved and no fresh credit arose in the relevant previous year. Disallowance of GST expenditure was sustained as allowable business outgo, the liability having crystallized during the year when input tax credit had lapsed. On alleged bogus purchases, ITAT endorsed CIT(A)'s restriction of addition to a nominal gross profit rate, as books were audited, not rejected, and sales and stock records were accepted. Deletion of addition on alleged difference in purchases was also confirmed, the AO having miscompared net and gross figures.
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