Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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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