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...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
The ITAT upheld reassessment jurisdiction under the post-1.4.2021 search regime, holding that incriminating material is not a condition precedent for issuing notice under section 148 and that such material is to be examined in the reassessment proceedings; the challenge to the notice therefore failed. On merits, it deleted the section 68 and consequential section 69C additions on sale of investments, finding that the investments were earlier accepted in audited balance sheets and scrutiny, sale proceeds were received through banking channels from identified purchasers, and the additions rested mainly on uncorroborated third-party statements and seized material without cross-examination.
The ITAT upheld reassessment jurisdiction under the post-1.4.2021 search regime, holding that incriminating material is not a condition precedent for issuing notice under section 148 and that such material is to be examined in the reassessment proceedings; the challenge to the notice therefore failed. On merits, it deleted the section 68 and consequential section 69C additions on sale of investments, finding that the investments were earlier accepted in audited balance sheets and scrutiny, sale proceeds were received through banking channels from identified purchasers, and the additions rested mainly on uncorroborated third-party statements and seized material without cross-examination.
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