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 allowed the assessee-firm's appeal and deleted the addition made u/s 69A r/w s.115BBE on account of partners' capital introduction. It held that payments for land purchase were substantially made directly by partners from their bank accounts and duly reflected in registered sale deeds and corresponding journal entries, rendering the AO's factual assumption erroneous. ITAT further held that any unexplained capital introduced by partners is assessable, if at all, in the hands of the respective partners and not the firm. The statutory requirement to prove "source of source" inserted in s.68 w.e.f. 01.04.2023 was held inapplicable to AY 2017-18.
ITAT allowed the assessee-firm's appeal and deleted the addition made u/s 69A r/w s.115BBE on account of partners' capital introduction. It held that payments for land purchase were substantially made directly by partners from their bank accounts and duly reflected in registered sale deeds and corresponding journal entries, rendering the AO's factual assumption erroneous. ITAT further held that any unexplained capital introduced by partners is assessable, if at all, in the hands of the respective partners and not the firm. The statutory requirement to prove "source of source" inserted in s.68 w.e.f. 01.04.2023 was held inapplicable to AY 2017-18.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
