Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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Addition for unexplained investment could not stand where it rested only on third-party statements and seized material from another group entity, without any independent corroborative evidence linking the assessee to payment of on-money. The Tribunal also noted that denial of cross-examination when such third-party statements are relied upon vitiates the addition in natural justice terms. Following co-ordinate Bench decisions on identical facts involving the same group, it deleted the addition under section 69 and allowed the assessee's appeals for the relevant years.
Addition for unexplained investment could not stand where it rested only on third-party statements and seized material from another group entity, without any independent corroborative evidence linking the assessee to payment of on-money. The Tribunal also noted that denial of cross-examination when such third-party statements are relied upon vitiates the addition in natural justice terms. Following co-ordinate Bench decisions on identical facts involving the same group, it deleted the addition under section 69 and allowed the assessee's appeals for the relevant years.
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