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...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
Independent corroboration and a direct nexus with the assessee are presented as essential before search statements, loose papers or third-party records can support additions. The material discusses acceptance of documented consultancy expenditure where agreements, invoices, banking payments and tax deduction support services, while retracted statements and uncorroborated papers do not establish non-genuine expenditure. It also addresses alleged unaccounted sales, cash salaries, land on-money, unexplained money, and liaisoning or gift expenditure. For unexplained expenditure, actual incurrence must be proved before examining its source; estimates, ambiguous loose sheets, and uninvestigated retractions are insufficient. Third-party parallel records or off-portal order communications require evidence of unrecorded supply, cash receipt, dispatch, stock discrepancy, or other linkage to the assessee.
Independent corroboration and a direct nexus with the assessee are presented as essential before search statements, loose papers or third-party records can support additions. The material discusses acceptance of documented consultancy expenditure where agreements, invoices, banking payments and tax deduction support services, while retracted statements and uncorroborated papers do not establish non-genuine expenditure. It also addresses alleged unaccounted sales, cash salaries, land on-money, unexplained money, and liaisoning or gift expenditure. For unexplained expenditure, actual incurrence must be proved before examining its source; estimates, ambiguous loose sheets, and uninvestigated retractions are insufficient. Third-party parallel records or off-portal order communications require evidence of unrecorded supply, cash receipt, dispatch, stock discrepancy, or other linkage to the assessee.
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