Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
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 ...
Section 69C concerns whether the source of expenditure remains unexplained, not merely whether underlying purchases are alleged to be bogus. Documentary support for transactions and bank disbursements upon encashment of letters of credit may explain the funding source. Allegations that goods did not move or documents were forged require independent inquiry, verification, examination of beneficiary entities, or other cogent material. Where sales are accepted, an addition made under section 69C cannot be sustained by recasting it under a different provision. The discussion also addresses consequential taxation under section 115BBE.
Section 69C concerns whether the source of expenditure remains unexplained, not merely whether underlying purchases are alleged to be bogus. Documentary support for transactions and bank disbursements upon encashment of letters of credit may explain the funding source. Allegations that goods did not move or documents were forged require independent inquiry, verification, examination of beneficiary entities, or other cogent material. Where sales are accepted, an addition made under section 69C cannot be sustained by recasting it under a different provision. The discussion also addresses consequential taxation under section 115BBE.
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