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Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Suspicion cannot replace proof where business expenditure is supported by a complete documentary trail and no adverse material shows inflation or non-business use. The assessee produced issue and receipt vouchers, labour bills and banking records, the books were not rejected, stock records showed no discrepancy, and the labour charges were consistent with the jewellery manufacturing business and accepted turnover. The contractors responded to notices under section 133(6), and there was no evidence that cash withdrawn by them was routed back to the assessee. In the absence of any specific finding of bogus expenditure, the ITAT deleted the ad hoc disallowance of labour charges in full.
Suspicion cannot replace proof where business expenditure is supported by a complete documentary trail and no adverse material shows inflation or non-business use. The assessee produced issue and receipt vouchers, labour bills and banking records, the books were not rejected, stock records showed no discrepancy, and the labour charges were consistent with the jewellery manufacturing business and accepted turnover. The contractors responded to notices under section 133(6), and there was no evidence that cash withdrawn by them was routed back to the assessee. In the absence of any specific finding of bogus expenditure, the ITAT deleted the ad hoc disallowance of labour charges in full.
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