Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Unaccounted business receipts from a garment-export business were treated as business turnover, so only the embedded gross profit, rather than the full receipts, was taxable. Based on the audited profitability trend, the reported ITAT decision restricted the gross-profit estimate to 1% of aggregated unaccounted sales, including token-note receipts. Alleged cash-salary additions were deleted because the recipient's statements were contradictory, cross-examination denied cash or cheque salary, and no independent support existed. Additions for cash, a gold coin and foreign currency were also deleted because recorded balances, the gift explanation and client confirmation of currency ownership remained unrebutted.
Unaccounted business receipts from a garment-export business were treated as business turnover, so only the embedded gross profit, rather than the full receipts, was taxable. Based on the audited profitability trend, the reported ITAT decision restricted the gross-profit estimate to 1% of aggregated unaccounted sales, including token-note receipts. Alleged cash-salary additions were deleted because the recipient's statements were contradictory, cross-examination denied cash or cheque salary, and no independent support existed. Additions for cash, a gold coin and foreign currency were also deleted because recorded balances, the gift explanation and client confirmation of currency ownership remained unrebutted.
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