Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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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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