Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Bogus purchases from accommodation entry providers were not disallowed in full where the assessee's sales were undisputed and it had maintained quantitative details, stock records, purchase and sales registers, and banking trail. The Tribunal noted that the suppliers were found non-genuine in investigation, but the record did not support an inference that no purchases had been made at all. In such circumstances, only the profit element embedded in the alleged bogus purchases could be taxed, on the footing that goods may have been sourced from the grey market and bills obtained from named parties. The disallowance was therefore restricted to 10% and the balance addition was deleted.
Bogus purchases from accommodation entry providers were not disallowed in full where the assessee's sales were undisputed and it had maintained quantitative details, stock records, purchase and sales registers, and banking trail. The Tribunal noted that the suppliers were found non-genuine in investigation, but the record did not support an inference that no purchases had been made at all. In such circumstances, only the profit element embedded in the alleged bogus purchases could be taxed, on the footing that goods may have been sourced from the grey market and bills obtained from named parties. The disallowance was therefore restricted to 10% and the balance addition was deleted.
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