Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
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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