Retraction of search statement and lack of corroboration cannot sustain an addition without independent incriminating material.
Charitable exemption denied where routed donations were used through the assessee's account as part of a tax-claim arrangement.
Inordinate delay in recording section 153C satisfaction quashes search-related proceedings, while parallel reassessment did not defeat jurisdiction.
RBI penalty deduction allowed, CSR disallowance sustained, and fresh appellate claims remitted for merits consideration.
Trust accumulation under section 11(2) upheld where purposes matched objects and fixed deposits were permissible investments.
Taxability of grant interest, TDS credit and MAT adjustments turned on Rule 37BA, section 115JB and section 234A limits
Transfer pricing, branch expense, and head-office interest issues resolved in assessee's favour by the Tribunal.
TNMM comparability turns on material margin distortion, turnover filters, and functional analysis in transfer pricing benchmarking.
Evidence-based remand in business expense, transfer pricing and TDS credit dispute; clerical error did not defeat credit note genuineness.
Reassessment notices and faceless assessment rules were remitted after retrospective amendments changed the statutory basis of pending challenges.
Additional evidence in appeal requires Rule 46A compliance; Assessing Officer must get opportunity to verify and comment before relief is granted.
On-money in property sale counts as additional consideration, not unexplained money, when the buyer source is identified.
Contractual interest liability on capital bond funds was deductible against related interest income under the agreement.
Unexplained jewellery additions fail where family customs, gifts, bills and bank records support reasonable possession and ownership.
Transfer pricing adjustment on interest to an associated enterprise remanded after admission of additional evidence.
CUP benchmarking accepts public commodity broker quotations where reliability is unchallenged, leading to deletion of transfer pricing adjustment.
Jurisdictional challenge to reassessment and unsupported reduction of accommodation-entry commission estimate were rejected by the tribunal.
Development agreement possession for limited construction purposes did not create a taxable transfer; capital gains addition deleted.
Pre-primary education qualifies as charitable education, and alleged section 13 issues cannot by themselves deny registration.
Unexplained investment penalty under section 271AAC upheld where quantum finding stood final and statutory immunity conditions were unmet.
TaxTMI 
TaxTMI 
of 1986 
