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...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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ITAT upheld rejection of the books of account because the assessee's cash sales, cash on hand and pre-demonetisation cash deposits showed an abnormal rise, while the supporting invoices were incomplete, generic and not backed by genuine evidence, so the accounts did not reflect a true and correct picture of business. On unexplained demonetisation-period cash deposits, the Tribunal accepted credit for the opening cash balance and bank withdrawals where no discrepancy was found, and sustained addition only for the balance amount remaining unexplained. It further held that the sustained addition under section 68 was taxable at the special rate under section 115BBE for AY 2017-18.
ITAT upheld rejection of the books of account because the assessee's cash sales, cash on hand and pre-demonetisation cash deposits showed an abnormal rise, while the supporting invoices were incomplete, generic and not backed by genuine evidence, so the accounts did not reflect a true and correct picture of business. On unexplained demonetisation-period cash deposits, the Tribunal accepted credit for the opening cash balance and bank withdrawals where no discrepancy was found, and sustained addition only for the balance amount remaining unexplained. It further held that the sustained addition under section 68 was taxable at the special rate under section 115BBE for AY 2017-18.
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