Noting that neither the Assessing Officer nor the CIT(A) have taken into consideration the explanation offered by the Assessee during the assessment proceedings in relation to the difference in the.
Finding that the Settlement Commission has not discarded the evidentiary value of the statement of witness (Rajesh Doshi) who has admitted to the modus operandi of availing bogus purchase bill from.
The Mumbai ITAT confirmed the CIT(A) s action in deleting the addition made on account of waiver of royalty received from two subsidiaries. The Bench comprising Prashant Maharishi (Accountant.
Since the AO did not consider that assessee has incurred expenses as per the terms & conditions of the agreement, the Mumbai ITAT directed the AO to allow the claim of the assessee to treat Form.
Finding that the AO has completely relied on the statement of third party without giving opportunity to the assessee to prove its point of view, which is against natural justice, the Mumbai ITAT.