Benami transaction and beneficial ownership: documentary and circumstantial evidence show payors were true beneficiaries, resulting in PBPTA consequen...
Denial of Preferential Treatment under SAFTA overturned where unchallenged Country of Origin certificate warranted exemption under Notification benefi...
Continuing offence of money-laundering: discharge set aside and proceedings reinstated where laundering continued after inclusion of predicate offence...
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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