Search and seizure: abatement of earlier search bars use of prior seized material in later search-based assessments; relief limited to new documents f...
Admission of additional evidence under remand rules must await a meaningful remand report; failure to do so breaches natural justice and mandates rema...
Disallowance of salary expenses was reversed where the taxpayer produced employee-wise breakup, designations, locations and salary details and no evidence of sham payments or diversion of funds was shown; AO's salary disallowance deleted. Non-deduction of tax at source on cross-border/reimbursement payments was held not to be a standalone ground for disallowance where payments were characterised as reimbursements, supported by particulars and did not prima facie attract TDS; 40(a)(i) addition deleted. Addition for alleged undisclosed receipts was deleted after the assessee furnished corresponding receipt particulars and TDS credit documentation, and Revenue produced no contrary proof. Appeal dismissed.
Disallowance of salary expenses was reversed where the taxpayer produced employee-wise breakup, designations, locations and salary details and no evidence of sham payments or diversion of funds was shown; AO's salary disallowance deleted. Non-deduction of tax at source on cross-border/reimbursement payments was held not to be a standalone ground for disallowance where payments were characterised as reimbursements, supported by particulars and did not prima facie attract TDS; 40(a)(i) addition deleted. Addition for alleged undisclosed receipts was deleted after the assessee furnished corresponding receipt particulars and TDS credit documentation, and Revenue produced no contrary proof. Appeal dismissed.
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