Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Addition for unexplained expenditure on alleged bogus purchases was deleted because the books of account were not rejected and there was no tangible material showing that the purchases were inflated, bogus or otherwise unexplained. The assessee had produced primary records, including books, stock and purchase registers, bank statements, import documents and supplier ledgers, and the department did not discredit the quantitative or banking evidence; an ad hoc percentage disallowance could not replace proof. On the TDS mismatch issue arising from Form 26AS discrepancies, the direction to verify the assessee's claim of revised TDS returns and delete the addition if supported was upheld.
Addition for unexplained expenditure on alleged bogus purchases was deleted because the books of account were not rejected and there was no tangible material showing that the purchases were inflated, bogus or otherwise unexplained. The assessee had produced primary records, including books, stock and purchase registers, bank statements, import documents and supplier ledgers, and the department did not discredit the quantitative or banking evidence; an ad hoc percentage disallowance could not replace proof. On the TDS mismatch issue arising from Form 26AS discrepancies, the direction to verify the assessee's claim of revised TDS returns and delete the addition if supported was upheld.
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