Minimum alternate tax exclusions for pre-amendment banking companies and expatriate Indian branch salaries remain outside head office expenditure limi...
Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Documentary evidence of purchase, holding and sale of listed shares, including contract notes, demat records and bank statements, was sufficient to discharge the initial onus of genuineness. General investigation-wing material on alleged penny stock accommodation entries could not sustain an addition under section 68 without independent inquiry or specific adverse evidence linking the assessee or broker to price manipulation. Denial of cross-examination of the persons whose statements were relied on further weakened the revenue case. As the section 68 addition failed, the consequential commission addition under section 69C also fell and was deleted.
Documentary evidence of purchase, holding and sale of listed shares, including contract notes, demat records and bank statements, was sufficient to discharge the initial onus of genuineness. General investigation-wing material on alleged penny stock accommodation entries could not sustain an addition under section 68 without independent inquiry or specific adverse evidence linking the assessee or broker to price manipulation. Denial of cross-examination of the persons whose statements were relied on further weakened the revenue case. As the section 68 addition failed, the consequential commission addition under section 69C also fell and was deleted.
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