Commercial vehicle depreciation, scientifically determined warranty provisions and exempt-income disallowances were resolved in favour of the taxpayer...
Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
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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