Once CESTAT had given a findings that the purchases in question were not bogus, then, additions proposed to be made on the basis of show-cause notice from Central Excise Directorate had no basis which the same could be sustained.
Some workmen had continued with IIT-Bombay through multiple contractors, therefore, for the limited purpose of payment of gratuity, Respondents were required to be treated as employee of IIT-Bombay.
During the course of assessment proceedings, AO noticed that on verification of the return of income for the A.Y 2015-16, it was seen that the opening stock was shown at Rs.17,98,60,568/-, whereas the closing stock as per the return filed for the A.Y 2014-15 was nil.
The onus was on assessee to demonstrate the extent of such assets which could be explained as having been acquired through funds which had been disclosed to the Department.
Where assessee was able to demonstrate that the transaction was included in the GSTR-1 Return as a zero-rated sale, the goods detained under Section 129(3) should be released provisionally.
Section 36(1)(vii) of ITA applied separately to non-rural debts, while Section 36(1)(viia) of the tax statute only applied to rural debts, making it clear that banks were entitled to claim both deductions, provided they pertained to different types of advances.
The failure of assessee to make the requisite disclosures in Schedule D would neither detract from the relief which had been accorded by AO nor change the factum of carry forward and set off as forming part of the assessment order.
Merely relying on the statement of a third party without any corroborating evidence could not justify income tax additions. In the absence of incriminating material found during a search, AO could not enhance the taxable income in proceedings under section 153A.
Since an Arresting Officer had conveyed his intention, reasons, grounds and believe to arrest assessee, the order of grounds of arrest was in conformity with the requirement of Section 19 of PMLA Act.
Interest income from bank deposits is eligible for deduction under Section 80P(2)(a)(i) as the funds in the voluntary reserves which were utilized for investment by the co-operative banks were the funds generated from the banking business.
