Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Reassessment based only on Investigation Wing material was held invalid where the recorded reasons showed no independent inquiry, no tangible material and no live nexus between the information and alleged escapement; in cases reopened beyond four years after scrutiny assessment, the absence of any identified failure to disclose fully and truly also barred jurisdiction. On merits, additions treating share sale proceeds as unexplained credits were deleted because the assessees had already disclosed the corresponding capital gains or losses and supported the transactions with contract notes, bank and demat records, broker ledgers and tax evidence, making a further addition impermissible double addition. General investigation or SEBI material without assessee-specific linkage could not sustain a penny stock allegation. Consequential commission additions were also deleted.
Reassessment based only on Investigation Wing material was held invalid where the recorded reasons showed no independent inquiry, no tangible material and no live nexus between the information and alleged escapement; in cases reopened beyond four years after scrutiny assessment, the absence of any identified failure to disclose fully and truly also barred jurisdiction. On merits, additions treating share sale proceeds as unexplained credits were deleted because the assessees had already disclosed the corresponding capital gains or losses and supported the transactions with contract notes, bank and demat records, broker ledgers and tax evidence, making a further addition impermissible double addition. General investigation or SEBI material without assessee-specific linkage could not sustain a penny stock allegation. Consequential commission additions were also deleted.
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