Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Third-party seized documents cannot, by themselves, sustain an addition where the assessee denies receipt of cash and no independent corroboration such as a cash trail or confirmation is produced; the ITAT held that the presumption under section 132(4A) read with section 292C does not operate against an assessee for material found at a third party's premises, so the addition failed. A receipt linked to a joint development agreement could not be taxed as income from other sources under section 56 without first examining whether it arose from a transfer of a capital asset and the correct year of taxability under the capital gains provisions; as the required transfer analysis was not undertaken, the addition was deleted.
Third-party seized documents cannot, by themselves, sustain an addition where the assessee denies receipt of cash and no independent corroboration such as a cash trail or confirmation is produced; the ITAT held that the presumption under section 132(4A) read with section 292C does not operate against an assessee for material found at a third party's premises, so the addition failed. A receipt linked to a joint development agreement could not be taxed as income from other sources under section 56 without first examining whether it arose from a transfer of a capital asset and the correct year of taxability under the capital gains provisions; as the required transfer analysis was not undertaken, the addition was deleted.
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