Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
In unabated assessments, additions under section 153A must rest on year-specific incriminating material; the Tribunal held that a loose sheet containing only rough notings, unrelated to the relevant assessment years, could not support presumed receipt of unaccounted cash from property sales, and the additions were deleted. It also held that section 69A could not apply where the assessee was not shown as buyer, seller, confirming party or beneficiary, and the receipts were plausibly explained as brokerage-related signatures without any corroborative evidence of ownership, possession or cash flow to the assessee. Both surviving additions were therefore unsustainable and were deleted.
In unabated assessments, additions under section 153A must rest on year-specific incriminating material; the Tribunal held that a loose sheet containing only rough notings, unrelated to the relevant assessment years, could not support presumed receipt of unaccounted cash from property sales, and the additions were deleted. It also held that section 69A could not apply where the assessee was not shown as buyer, seller, confirming party or beneficiary, and the receipts were plausibly explained as brokerage-related signatures without any corroborative evidence of ownership, possession or cash flow to the assessee. Both surviving additions were therefore unsustainable and were deleted.
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