Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
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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