Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Documented listed-share transactions cannot be treated as non-genuine merely because they yielded extraordinary profits, involved a penny stock, or reflected adverse company indicators. In the absence of evidence linking the taxpayer to price rigging, entry operators or other manipulation, the alleged capital-gains addition and consequential commission expenditure were deleted. Unsecured loans were accepted as explained based on lenders' tax returns, confirmations, bank statements and a corporate lender's affidavit. A life-insurance premium deduction was also allowed because the record showed adjustment in the relevant financial year, despite the receipt's later assessment-year reference.
Documented listed-share transactions cannot be treated as non-genuine merely because they yielded extraordinary profits, involved a penny stock, or reflected adverse company indicators. In the absence of evidence linking the taxpayer to price rigging, entry operators or other manipulation, the alleged capital-gains addition and consequential commission expenditure were deleted. Unsecured loans were accepted as explained based on lenders' tax returns, confirmations, bank statements and a corporate lender's affidavit. A life-insurance premium deduction was also allowed because the record showed adjustment in the relevant financial year, despite the receipt's later assessment-year reference.
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