Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability ...
Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
Section 80P deduction for co-operative societies remains available despite nominal members and housing society status, with limited interest income tr...
In corporate assessments of unexplained share capital and share premium, documented traceability via ITR acknowledgments, PAN details and bank statements through legitimate channels is accorded greater evidentiary weight than the Assessing Officer's subjective "Test of Human Probability"; accordingly the addition was deleted. The ratio in NRA Iron & Steel is confined to phantom or nonexistent subscribers that cannot be traced; it does not apply where subscribers are verifiable and creditworthy. Revenue must prove a direct "live link" showing funds originated from the assessee's own coffers; absent contrary material, Tribunal factual findings upholding castiron documentary evidence prevail and no substantial question of law arises.
In corporate assessments of unexplained share capital and share premium, documented traceability via ITR acknowledgments, PAN details and bank statements through legitimate channels is accorded greater evidentiary weight than the Assessing Officer's subjective "Test of Human Probability"; accordingly the addition was deleted. The ratio in NRA Iron & Steel is confined to phantom or nonexistent subscribers that cannot be traced; it does not apply where subscribers are verifiable and creditworthy. Revenue must prove a direct "live link" showing funds originated from the assessee's own coffers; absent contrary material, Tribunal factual findings upholding castiron documentary evidence prevail and no substantial question of law arises.
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