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. 68 for unsecured loans was held unsustainable where the assessee furnished confirmations/affidavits, bank statements showing availability of funds, and banking-channel transfers, thereby establishing identity, creditworthiness, and genuineness; the AO, despite having complete particulars, made no independent verification by issuing summons/notices under s. 133(6) and relied only on suspicion regarding low income or cash deposits, which could not substitute evidence, and the Finance Act, 2022 second proviso to s. 68 was held inapplicable to AY 2016-17; the addition was deleted. Ad hoc disallowance of expenses for want of vouchers was restricted from 20% to 5% as reasonable. - ITAT
Addition under s. 68 for unsecured loans was held unsustainable where the assessee furnished confirmations/affidavits, bank statements showing availability of funds, and banking-channel transfers, thereby establishing identity, creditworthiness, and genuineness; the AO, despite having complete particulars, made no independent verification by issuing summons/notices under s. 133(6) and relied only on suspicion regarding low income or cash deposits, which could not substitute evidence, and the Finance Act, 2022 second proviso to s. 68 was held inapplicable to AY 2016-17; the addition was deleted. Ad hoc disallowance of expenses for want of vouchers was restricted from 20% to 5% as reasonable. - ITAT
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