Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Recorded bank credits supported by books of account, confirmations, returns, ledgers and bank statements could not be treated as unexplained money under section 69A, because the assessee was not shown to be the owner of unrecorded money and the addition lacked corroborative evidence that the funds were undisclosed income. The deletion of the addition, including the cash deposit component, was upheld. Reassessment also failed because the recorded reasons rested on incorrect facts: the assessee was said to have three bank accounts and higher non-cash credits, but verification showed only one bank account and the alleged information was wrong. The section 148 notice and reassessment proceedings were therefore held unsustainable.
Recorded bank credits supported by books of account, confirmations, returns, ledgers and bank statements could not be treated as unexplained money under section 69A, because the assessee was not shown to be the owner of unrecorded money and the addition lacked corroborative evidence that the funds were undisclosed income. The deletion of the addition, including the cash deposit component, was upheld. Reassessment also failed because the recorded reasons rested on incorrect facts: the assessee was said to have three bank accounts and higher non-cash credits, but verification showed only one bank account and the alleged information was wrong. The section 148 notice and reassessment proceedings were therefore held unsustainable.
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