Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
Penny-stock share sale proceeds cannot be treated as unexplained money merely on suspicion of accommodation entries where purchases and sales occurred through banking channels, demat accounts and the stock exchange. Investigation findings about broker manipulation require material linking the taxpayer to bogus purchases, cash exchanges, price rigging or an entry arrangement; absent such evidence, documentary transaction records prevail and the addition is unsustainable. Exempt long-term capital gains nevertheless require disclosure through a return, and failure to file a return for the relevant year can justify reassessment proceedings.
Penny-stock share sale proceeds cannot be treated as unexplained money merely on suspicion of accommodation entries where purchases and sales occurred through banking channels, demat accounts and the stock exchange. Investigation findings about broker manipulation require material linking the taxpayer to bogus purchases, cash exchanges, price rigging or an entry arrangement; absent such evidence, documentary transaction records prevail and the addition is unsustainable. Exempt long-term capital gains nevertheless require disclosure through a return, and failure to file a return for the relevant year can justify reassessment proceedings.
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