S. 69C : Unexplained expenditure-Bogus purchases-Trading in Iron and steel scrap-Sales not disputed-Regular transaction with supplier-Ledger confirmation of supplier-Order of CIT(A) deleting the addition is affirmed. [S. 143(3)]
S. 69C : Unexplained expenditure-Bogus purchases-Trading in Iron and steel scrap-Sales not disputed-Regular transaction with supplier-Ledger confirmation of supplier-Order of CIT(A) deleting the addition is affirmed. [S. 143(3)]
S. 69C : Unexplained expenditure-Income from undisclosed Sources-Survey-Accommodation entries-Bogus purchases-Addition to the extent of 12.5 Per Cent is affirmed-Reassessment is affirmed. [S.133(6) 139, 147, 148]
S. 69C : Unexplained expenditure-Bogus purchases-Sales accepted-Disallowance of purchases are deleted.[S. 37(1)]
S. 68 : Cash credits-Cash Deposits-Demonetisation period-Cash sales explained-Basis of cash sales made in earlier financial year can not be adopted as a parameter for accepting cash sales made during year.
S. 61 : Revocable transfer of assets-Trust-Association Of Persons-Stressed Assets Of Banks And Financial Institutions Acquired By ARCIL by setting up Trusts and formulating schemes-Trust is not an Association of persons-No discretion is given to trustee to decide allocation of income every year, nor right given to beneficiary to exercise option to receive income or not-Income liable to be assessed in hands of beneficiaries-Respective shares known since inception-Assessee could not be considered as an indeterminate trust. [S. 63, Indian Trusts Act, 1882, S. 7, 9, Securitisation And Reconstruction Of Financial Assets And Enforcement Of Security Interest Act, 2002]
S. 41(1) : Profits chargeable to tax-Remission or cessation of trading liability-Excess cash, stale drafts and branch suspense account-Transferred to depositors’ education and awareness fund-Cannot be treated as income-Deletion of addition is affirmed. [S.28 (iv)]
S. 40(a)(ii) : Amounts not deductible-Rates or tax-Education cess-Not an allowable deduction.
S. 40(a)(ia): Amounts not deductible-Deduction at source-Making Provision for expenses at end of accounting year-No tax deducted at source-Deducting tax at source in subsequent year and depositing it before due date for filing of return of income.[S.139(1)]
S. 40(a)(ia): Amounts not deductible-Deduction at source-Interest-Payment of deposits-Disallowance of 30 per cent of interest-Deductees have already filed return and paid tax-Matter remanded. [S.194A, 197, Form 15 G, 15H]
S 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Commission-Procurement of orders overseas-No disallowance can be made for failure to deduct tax at source.[S. 5,9(1)(vii),195]