S.143(3): Assessment-Accrual-Mercantile system of accounting-Professional and technical services-Sale of judgement text-Right to receive income accruing under agreement arising only on satisfaction of conditions stipulated in agreement-Order of CIT(A) deleting the addition is affirmed. [S. 5, 194J]
S. 143(3): Assessment-Search and seizure-Undisclosed sales-CIT(A) restricted profit element at 8 per Cent of sales-Credit to be given to income surrendered. [S. 132]
S. 133A : Power of survey-Income from undisclosed sources-Construction of commercial and residential buildings-Director disowning contents of paper found in the course of survey-Addition is deleted. [S. 133(6)]
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Functional analysis-Re seller-Performing marketing support service-Foreign exchange gains-Other grounds-Matter remanded to Commissioner (Appeals) for Re adjudication. [S. 251]
S. 92BA : Transfer pricing-Specified domestic transaction-Arm’s length price-Avoidance of tax-Excluded from definition with effect from 1-4-2017-Omission has retrospective effect-Addition is deleted. [S.40A(2)(b)]
S. 80HHC : Export-Manufacturing and letting out vacuum insulated tanks and related products-Lease rent-Business income-Eligible for deduction-Deduction not to be allowed on profits to extent deduction already allowed under Section 8OIA of the Act.
S. 80G : Donation-Mentioning wrong section code-Error typographical and inadvertent-Remanded to Commissioner (E) to treat application under proper section code-Circular No. 7 Of 2024, Dated 25-4-2024 (2024) 463 ITR 14(St). [S.80G(5), Form No 10B].
S. 69C : Unexplained expenditure-Information from Investigation Wing-Purchase transaction is duly explained with supporting evidences-Addition is deleted-Reassessment issue is left open. [S. 147, 148]
S. 69A : Unexplained money-Remand report-Single percentage of Commission for both receipts is not p roper-Matter remanded to Assessing Officer to reconsider issue and apply appropriate rate for estimation of income. [S. 147,148]
S. 69A : Unexplained money-Sales-Demonetisation-Deletion of addition is affirmed.