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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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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