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...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
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Additions under s.69A for alleged unexplained bank deposits and under s.69C for alleged unexplained cash purchases were examined in light of documentary evidence supporting purchases from farmers through a government-regulated APMC mandi. The assessee produced mandi certificates evidencing payment of statutory mandi and development charges and furnished Form 6R substantiating the purchases. Since the purchases were routed through a government body and were corroborated by contemporaneous records, the genuineness of the purchases could not be doubted and the presumption of unexplained expenditure was not attracted. Consequently, deletion of the s.69C additions was upheld and the appeal of the revenue was dismissed. - ITAT
Additions under s.69A for alleged unexplained bank deposits and under s.69C for alleged unexplained cash purchases were examined in light of documentary evidence supporting purchases from farmers through a government-regulated APMC mandi. The assessee produced mandi certificates evidencing payment of statutory mandi and development charges and furnished Form 6R substantiating the purchases. Since the purchases were routed through a government body and were corroborated by contemporaneous records, the genuineness of the purchases could not be doubted and the presumption of unexplained expenditure was not attracted. Consequently, deletion of the s.69C additions was upheld and the appeal of the revenue was dismissed. - ITAT
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