Co-operative society's mandatory reserve and share capital fixed deposits with banks-interest treated as business income under 80P(2)(a)(iii) deductio...
Income tax reassessment reopening after four years on investigation tip, without s.147 proviso disclosure failure, struck down as borrowed satisfactio...
ITAT allowed the assessee's appeal. Additions on account of cash and jewellery seized during search were quashed as the assets were not found at premises of the AOP or its members and the consortium itself was not a legal entity. Additions for alleged bogus purchases from three suppliers were deleted, the Tribunal holding that payments were routed through banking channels, recognized in an arbitral award, and advances written off due to delay could not be treated as non-genuine. Disallowance of expenses was also set aside since payments were by cheque with TDS and duly accounted in the AOP's financials. The TP adjustment, based on an improper application of CUP without comparables and contrary to earlier directions, was held unsustainable and the corresponding addition was set aside.
ITAT allowed the assessee's appeal. Additions on account of cash and jewellery seized during search were quashed as the assets were not found at premises of the AOP or its members and the consortium itself was not a legal entity. Additions for alleged bogus purchases from three suppliers were deleted, the Tribunal holding that payments were routed through banking channels, recognized in an arbitral award, and advances written off due to delay could not be treated as non-genuine. Disallowance of expenses was also set aside since payments were by cheque with TDS and duly accounted in the AOP's financials. The TP adjustment, based on an improper application of CUP without comparables and contrary to earlier directions, was held unsustainable and the corresponding addition was set aside.
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