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...
ITAT held that gifts credited through banking channels were not taxable under section 69A absent corroborative evidence that they represented the assessee's own unaccounted money, and the addition was deleted. Cash received as on-money on property sales could not be taxed as unexplained money under section 69A; it had to be included in sale consideration and assessed under capital gains. Additions based only on uncorroborated Excel sheets for alleged construction were rejected. Major jewellery additions were partly explained by family and customary gifts, with the balance sustained, and telescoping was allowed against confirmed on-money receipts. Cash found during search was sustained, but telescoping was granted. The watch-related addition was deleted on proof of ownership and independent verification.
ITAT held that gifts credited through banking channels were not taxable under section 69A absent corroborative evidence that they represented the assessee's own unaccounted money, and the addition was deleted. Cash received as on-money on property sales could not be taxed as unexplained money under section 69A; it had to be included in sale consideration and assessed under capital gains. Additions based only on uncorroborated Excel sheets for alleged construction were rejected. Major jewellery additions were partly explained by family and customary gifts, with the balance sustained, and telescoping was allowed against confirmed on-money receipts. Cash found during search was sustained, but telescoping was granted. The watch-related addition was deleted on proof of ownership and independent verification.
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