Drawings/designs supply and erection supervision fees from German contractor: designs non-taxable; supervision taxed as FTS/PE depending on six-month ...
Addition for alleged unexplained cash receipts based solely on an excel sheet/ledger seized from a third party and a statement recorded from that third party was held unsustainable because the assessee was not furnished the relied-upon seized material or statement and was denied an effective opportunity to cross-examine the witness, constituting a breach of natural justice. In the absence of any direct or corroborative evidence linking the assessee to the alleged receipts, the material was treated as merely circumstantial and insufficient to support the addition. The impugned addition was deleted and the appeal was allowed - ITAT
Addition for alleged unexplained cash receipts based solely on an excel sheet/ledger seized from a third party and a statement recorded from that third party was held unsustainable because the assessee was not furnished the relied-upon seized material or statement and was denied an effective opportunity to cross-examine the witness, constituting a breach of natural justice. In the absence of any direct or corroborative evidence linking the assessee to the alleged receipts, the material was treated as merely circumstantial and insufficient to support the addition. The impugned addition was deleted and the appeal was allowed - ITAT
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