Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
Deductibility of settlement payments for securities law penalties and treatment of unexplained cash credits in share trading -- Tribunal upholds posit...
Threshold for allottee-initiated insolvency petitions in leasehold real estate upheld; petition admitted after possession letters deemed legally ineff...
Contravention of foreign exchange rules in crossborder diamond payments; appellate tribunal reduces one appellant's penalty for delay and proportional...
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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