Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability ...
Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
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A receipt under a collaboration agreement was treated as a business transaction, not an unexplained cash credit, because it moved through account-to-account banking channels and the payer's bank account showed no cash deposit before transfer. The assessee produced corporate records, PAN, returns, accounts and bank statements establishing identity, creditworthiness and genuineness; once that material was filed, the burden shifted to the department, which was not discharged. The Tribunal found the accommodation entry allegation unsupported by enquiry and based on suspicion, and deleted the section 68 addition. The reassessment ground was left open and not decided.
A receipt under a collaboration agreement was treated as a business transaction, not an unexplained cash credit, because it moved through account-to-account banking channels and the payer's bank account showed no cash deposit before transfer. The assessee produced corporate records, PAN, returns, accounts and bank statements establishing identity, creditworthiness and genuineness; once that material was filed, the burden shifted to the department, which was not discharged. The Tribunal found the accommodation entry allegation unsupported by enquiry and based on suspicion, and deleted the section 68 addition. The reassessment ground was left open and not decided.
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