Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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Sale advances supported by a seized agreement, receipt and subsequent conveyance were treated as explained sale consideration rather than unexplained money under section 69A. The notes state that any suppressed consideration would instead be considered under capital gains in the relevant assessment year, and the section 69A additions were vacated. For section 153C, the relevant date for exclusion is stated to be the search initiation date, not later receipt of seized material; the deeming provision is confined to identifying abated assessment years, so the jurisdictional challenge failed. The mechanical-approval challenge under section 153D also failed for lack of cogent supporting material. The consolidated satisfaction-note issue remained open.
Sale advances supported by a seized agreement, receipt and subsequent conveyance were treated as explained sale consideration rather than unexplained money under section 69A. The notes state that any suppressed consideration would instead be considered under capital gains in the relevant assessment year, and the section 69A additions were vacated. For section 153C, the relevant date for exclusion is stated to be the search initiation date, not later receipt of seized material; the deeming provision is confined to identifying abated assessment years, so the jurisdictional challenge failed. The mechanical-approval challenge under section 153D also failed for lack of cogent supporting material. The consolidated satisfaction-note issue remained open.
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