Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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Where the assessee failed to produce cogent evidence of employment, salary receipt, commission or brokerage, the Tribunal upheld denial of the claimed standard deduction and treated the returned income as unexplained money under section 69A for A.Ys. 2019-20 and 2020-21. By contrast, where the assessee had opted for presumptive taxation under section 44AD and produced confirmations, sample bills and related business details, the Tribunal accepted that rice trading business was carried on and held that the same receipts could not again be taxed as unexplained money under section 69A, as that would amount to double taxation. The section 69A addition was deleted for A.Y. 2022-23, and the rice trading finding was applied for A.Y. 2021-22.
Where the assessee failed to produce cogent evidence of employment, salary receipt, commission or brokerage, the Tribunal upheld denial of the claimed standard deduction and treated the returned income as unexplained money under section 69A for A.Ys. 2019-20 and 2020-21. By contrast, where the assessee had opted for presumptive taxation under section 44AD and produced confirmations, sample bills and related business details, the Tribunal accepted that rice trading business was carried on and held that the same receipts could not again be taxed as unexplained money under section 69A, as that would amount to double taxation. The section 69A addition was deleted for A.Y. 2022-23, and the rice trading finding was applied for A.Y. 2021-22.
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