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Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Assessee successfully contested disallowances: the Tribunal found proportionate interest disallowance under section 36(1)(iii) unjustified because loans and advances were funded from the assessee's own interest-free funds and repayments demonstrated genuineness; reimbursement payments for staff training to Mahindra & Mahindra Ltd. did not attract TDS under section 194C and so section 40(a)(ia) disallowance was deleted; discrepancies between income in the return and Form 26AS were attributable to legitimate business adjustments and the assessee explained RTO reimbursements, so additions and the section 40A(3) cash expenditure disallowance were deleted. The appeal was allowed in entirety.
Assessee successfully contested disallowances: the Tribunal found proportionate interest disallowance under section 36(1)(iii) unjustified because loans and advances were funded from the assessee's own interest-free funds and repayments demonstrated genuineness; reimbursement payments for staff training to Mahindra & Mahindra Ltd. did not attract TDS under section 194C and so section 40(a)(ia) disallowance was deleted; discrepancies between income in the return and Form 26AS were attributable to legitimate business adjustments and the assessee explained RTO reimbursements, so additions and the section 40A(3) cash expenditure disallowance were deleted. The appeal was allowed in entirety.
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