Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Derivative option losses claimed through a recognised exchange and registered broker require independent proof of genuineness where investigation material indicates manipulated transactions. Contract notes and banking-channel payments alone were insufficient in light of broker admissions, options acquired shortly before expiry and allowed to lapse, and repeated losses; the taxpayer did not rebut this material, so the loss disallowance was sustained. Jurisdictional objections to reassessment, raised specifically before the Tribunal and requiring factual verification, were admitted but remanded to the appellate authority for detailed adjudication. The appeal was partly allowed for statistical purposes.
Derivative option losses claimed through a recognised exchange and registered broker require independent proof of genuineness where investigation material indicates manipulated transactions. Contract notes and banking-channel payments alone were insufficient in light of broker admissions, options acquired shortly before expiry and allowed to lapse, and repeated losses; the taxpayer did not rebut this material, so the loss disallowance was sustained. Jurisdictional objections to reassessment, raised specifically before the Tribunal and requiring factual verification, were admitted but remanded to the appellate authority for detailed adjudication. The appeal was partly allowed for statistical purposes.
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