Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Documented acquisition, dematerialised holdings, exchange-based sales and banking records support the genuineness of share-trading losses unless independent material links the taxpayer to accommodation entries, manipulation, unaccounted cash or collusion. General investigation material and third-party statements cannot be relied on without supplying adverse material and allowing cross-examination, as this breaches natural justice. Section 68 does not apply where dematerialised share sales explain the proceeds and the claimed loss reflects depletion of funds rather than an unexplained credit. Section 69B also cannot replace section 68 absent evidence that actual investment exceeded recorded investment, including unrecorded consideration or cash payments.
Documented acquisition, dematerialised holdings, exchange-based sales and banking records support the genuineness of share-trading losses unless independent material links the taxpayer to accommodation entries, manipulation, unaccounted cash or collusion. General investigation material and third-party statements cannot be relied on without supplying adverse material and allowing cross-examination, as this breaches natural justice. Section 68 does not apply where dematerialised share sales explain the proceeds and the claimed loss reflects depletion of funds rather than an unexplained credit. Section 69B also cannot replace section 68 absent evidence that actual investment exceeded recorded investment, including unrecorded consideration or cash payments.
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