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...
Addition under s.69C for alleged bogus purchases was unsustainable because the precondition for s.69C is proof of a genuinely incurred expenditure whose source remains unexplained. Since the assessee's books were not rejected under s.145(3), the purchases were recorded in regular books, and bank statements evidenced sufficient balances and payments, the source of the purchase expenditure was not in dispute. Consequently, s.69C could not be invoked, and the estimated disallowance/profit element addition at 12.5% of purchase value was deleted; the appeal was allowed. - ITAT
Addition under s.69C for alleged bogus purchases was unsustainable because the precondition for s.69C is proof of a genuinely incurred expenditure whose source remains unexplained. Since the assessee's books were not rejected under s.145(3), the purchases were recorded in regular books, and bank statements evidenced sufficient balances and payments, the source of the purchase expenditure was not in dispute. Consequently, s.69C could not be invoked, and the estimated disallowance/profit element addition at 12.5% of purchase value was deleted; the appeal was allowed. - ITAT
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