Reopening Assessments invalid where satisfaction and jurisdictional approval are absent for third party seized material, leading to quashing of assess...
Benami property exclusion from the insolvency estate: Benami Act proceedings preclude IBC tribunals from reopening attachments or treating such assets...
Exclusion of limitation period: pandemic suspension plus debtor acknowledgement can extend limitation, requiring fresh factfinding on guarantee invoca...
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Books of account of a project office cannot be rejected merely because no revenue was shown in the year and only expenditure was claimed; absent cogent material, such rejection is unsustainable, and the appellate deletion of its consequences was upheld. Additions made by treating a foreign exchange item as fees for technical services and by treating head office remittances as undisclosed income also failed because they were unsupported by substance or material evidence. The ITAT agreed with the Commissioner (Appeals) that the assessee's project-office receipts and remittances did not justify the impugned additions, and it dismissed the Revenue's appeal.
Books of account of a project office cannot be rejected merely because no revenue was shown in the year and only expenditure was claimed; absent cogent material, such rejection is unsustainable, and the appellate deletion of its consequences was upheld. Additions made by treating a foreign exchange item as fees for technical services and by treating head office remittances as undisclosed income also failed because they were unsupported by substance or material evidence. The ITAT agreed with the Commissioner (Appeals) that the assessee's project-office receipts and remittances did not justify the impugned additions, and it dismissed the Revenue's appeal.
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