S. 92C: Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-No TP adjustment where consistent benchmarking was accepted in an earlier year. [S.92CA]
S. 92C: Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-No TP adjustment where consistent benchmarking was accepted in an earlier year. [S.92CA]
S. 80G: Donation-Composite charitable and religious trust-Approval cannot be denied if religious expenditure does not exceed 5%.-Matter was remanded. [S. 80G(5), 80G(5B)]
S. 69C: Unexplained expenditure-Recorded expenditure cannot be taxed under section 69C [S. 143(3)]
S. 69C: Unexplained expenditure-Bogus purchases-Unverifiable Purchases-Only the profit element embedded in unverifiable purchases can be taxed and not the entire purchase amount-Estimation of 5% GP upheld. [S. 145(3)]
S. 69C: Unexplained expenditure-bogus purchases-Addition unsustainable where purchases, movement of goods and consumption are fully evidenced. [S. 145]
S. 69A: Unexplained money-Search & seizure-Addition based solely on employee’s diary and retracted statements-Not sustainable. (S. 132, 132(4A) 153A)
S. 69A: Unexplained money-Seized Papers-Where seized rough sheets substantially tally with the regular books of account, only unexplained differences can be sustained and not the entire addition. [S.132, 145(3)]
S. 69A: Unexplained money-Cash deposits during demonetisation-Addition was deleted where source stood explained from regular books [S. 115BBE]
S. 69A: Unexplained money-Survey-Addition based on dumb documents seized from third parties deleted.[S. 133A]
S. 69: Unexplained investments-Undisclosed Income-Loose papers-Addition based on dumb documents-Addition was deleted.[S.69C, 132, 153A]