International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
Transaction value between related persons requires market-equivalent pricing; importer must prove declared value mirrors ordinary international trade ...
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The note addresses tax consequences of undisputed TDS non-deduction and unexplained loan credits: the applicable disallowance for failure to deduct tax at source is confined to thirty percent of the admitted shortfall, limiting the assessor's large-scale disallowance to that proportion; and an addition treated as unexplained cash credit based on increased unsecured loans was deleted where the assessee furnished primary documents (confirmations, ITRs, bank statements), shifting the onus to the revenue to rebut those records and no adverse material was produced.
The note addresses tax consequences of undisputed TDS non-deduction and unexplained loan credits: the applicable disallowance for failure to deduct tax at source is confined to thirty percent of the admitted shortfall, limiting the assessor's large-scale disallowance to that proportion; and an addition treated as unexplained cash credit based on increased unsecured loans was deleted where the assessee furnished primary documents (confirmations, ITRs, bank statements), shifting the onus to the revenue to rebut those records and no adverse material was produced.
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