Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
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Long-term capital gains on share transactions were accepted as genuine where the assessee produced complete documentary evidence of purchase, amalgamation, dematerialisation, stock exchange sale, STT payment, broker records and banking receipts. The Tribunal held that such direct evidence discharged the burden of proof, and that suspicion, price movement and general human probabilities could not override it without independent inquiry or contrary material linking the assessee to an entry operator or rigging arrangement. As the share sale was treated as genuine, the consequential addition for alleged accommodation-entry commission under section 69C also failed and was deleted.
Long-term capital gains on share transactions were accepted as genuine where the assessee produced complete documentary evidence of purchase, amalgamation, dematerialisation, stock exchange sale, STT payment, broker records and banking receipts. The Tribunal held that such direct evidence discharged the burden of proof, and that suspicion, price movement and general human probabilities could not override it without independent inquiry or contrary material linking the assessee to an entry operator or rigging arrangement. As the share sale was treated as genuine, the consequential addition for alleged accommodation-entry commission under section 69C also failed and was deleted.
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