Timing mismatch in income recognition requires verification whether receipts were already taxed in an earlier year; matter remitted for fresh examinat...
FOB transaction value and export incentives: customs valuation cannot override contractual export benefits or support confiscation without valid proof...
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Protective addition failed where the cash allegedly routed for gold purchase was owned up by other persons and the assessee was shown only as a facilitator, so the cash could not be taxed in his hands. Commission income was also deleted in the Prateek Bansal gold transaction because Bansal admitted the transaction and its profit, and there was no material for a separate commission to the assessee. For the seized 2 kg gold, ownership remained unclear; verification from the Enforcement Directorate was directed before deciding whether it was assessable as commission in the assessee's hands or in the company's hands.
Protective addition failed where the cash allegedly routed for gold purchase was owned up by other persons and the assessee was shown only as a facilitator, so the cash could not be taxed in his hands. Commission income was also deleted in the Prateek Bansal gold transaction because Bansal admitted the transaction and its profit, and there was no material for a separate commission to the assessee. For the seized 2 kg gold, ownership remained unclear; verification from the Enforcement Directorate was directed before deciding whether it was assessable as commission in the assessee's hands or in the company's hands.
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