The Tribunal held that trading and service activities were inextricably linked and could not be segmented. It accepted entity-level TNMM, rendering TP adjustments unsustainable.
The Tribunal held that TDS credit cannot be denied merely because it does not appear under the assessee’s PAN. It ruled that the assessee cannot be forced to ensure revision of TDS returns by the deductor.
The Tribunal set aside the dismissal of a delayed appeal, holding that the issue of distribution fee taxability requires fresh examination on merits. The case was remanded to the Assessing Officer for reconsideration with proper hearing.
The Tribunal held that return of advances cannot be taxed under Section 68. The key takeaway is that explained transactions supported by records cannot be treated as unexplained income.
The issue was whether commission payments were genuine business expenses. The Tribunal held that disallowance based on non-response and suspicion was not justified. The key takeaway is that conjectures cannot replace evidence in tax assessments.
The case involved cash deposits during demonetization treated as unexplained income. The tribunal accepted the explanation of foreign remittances and deleted the addition, emphasizing lack of contrary evidence.
The case examined whether contract receipts reflected in Form 26AS but not disclosed as income could be taxed. The Tribunal upheld the addition, ruling that failure to report such receipts in any year makes them taxable in the year of receipt.
The Tribunal held that additions under Section 153C cannot be sustained when based on unverified third-party statements and documents. It found the evidence lacked credibility and was not corroborated. The ruling highlights strict evidentiary standards in search-based assessments.
The case involved addition on account of unexplained foreign remittances. The Tribunal held that failure to examine documentary evidence warranted remand for fresh adjudication.
The Tribunal held that loans received from NBFCs cannot be treated as unexplained where identity, creditworthiness, and genuineness are established. Absence of incriminating material led to deletion of additions.
