Customs valuation and import permissibility conflict resolved: accepted enhancement of transaction value removes liability for confiscation and penalt...
Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
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Section 69C was held inapplicable to an ad hoc disallowance of salary and wages recorded in the books, because the "source of such expenditure" stood explained from the regular books and the AO neither alleged out-of-books payments nor an unproved source; at most, the issue concerned allowability under section 37(1) on the ground of alleged excessiveness, so section 69C (and consequential taxation under section 115BBE) could not be invoked, resulting in deletion of the section 69C-based addition. Disallowance of workman and staff welfare expenses was sustained as both Members agreed to confirm it. - ITAT
Section 69C was held inapplicable to an ad hoc disallowance of salary and wages recorded in the books, because the "source of such expenditure" stood explained from the regular books and the AO neither alleged out-of-books payments nor an unproved source; at most, the issue concerned allowability under section 37(1) on the ground of alleged excessiveness, so section 69C (and consequential taxation under section 115BBE) could not be invoked, resulting in deletion of the section 69C-based addition. Disallowance of workman and staff welfare expenses was sustained as both Members agreed to confirm it. - ITAT
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