Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
Preventive suspension requires an immediate continuing threat and cannot become indefinite without inquiry, fresh evidence, or proportionate safeguard...
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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