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...
Disallowance under section 40(a)(ia) for alleged non deduction of TDS on contractual payments was rejected after appellate verification of party wise ledgers, TDS returns, certificates and tax audit reports; appellate authority found tax deducted where applicable and set aside the assessing officer's blanket disallowance. Alleged nondisclosure based on Form 26AS entries and invocation of section 145(3) was also rejected because the AO relied on incorrect or double counted figures and ignored reconciliations and the assessee's percentage of completion accounting; the appellate authority's acceptance of reconciliations led to deletion of the addition. Both revenue grounds were dismissed.
Disallowance under section 40(a)(ia) for alleged non deduction of TDS on contractual payments was rejected after appellate verification of party wise ledgers, TDS returns, certificates and tax audit reports; appellate authority found tax deducted where applicable and set aside the assessing officer's blanket disallowance. Alleged nondisclosure based on Form 26AS entries and invocation of section 145(3) was also rejected because the AO relied on incorrect or double counted figures and ignored reconciliations and the assessee's percentage of completion accounting; the appellate authority's acceptance of reconciliations led to deletion of the addition. Both revenue grounds were dismissed.
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