Concessional corporate tax option under section 115BAA survives procedural documentary lapses when statutory compliance and earlier exercise are estab...
Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
GST deregistration, subsequent non-filing of returns, a supplier's absence from its address, or vehicle discrepancies do not alone establish that documented purchases are bogus. Purchase orders, subcontract agreements, invoices, delivery records, e-way bills, GST records, attendance and project records, and banking payments support the genuineness of materials, labour, housekeeping and manpower transactions, particularly where books remain unrejected and contracts are undisputed. Incomplete third-party statements or chat extracts not supplied to the taxpayer, and not linked to its transactions, lack evidentiary force. Revenue must establish a nexus between alleged supplier fund diversion and taxpayer transactions; a taxpayer denying a transaction cannot be required to prove a negative.
GST deregistration, subsequent non-filing of returns, a supplier's absence from its address, or vehicle discrepancies do not alone establish that documented purchases are bogus. Purchase orders, subcontract agreements, invoices, delivery records, e-way bills, GST records, attendance and project records, and banking payments support the genuineness of materials, labour, housekeeping and manpower transactions, particularly where books remain unrejected and contracts are undisputed. Incomplete third-party statements or chat extracts not supplied to the taxpayer, and not linked to its transactions, lack evidentiary force. Revenue must establish a nexus between alleged supplier fund diversion and taxpayer transactions; a taxpayer denying a transaction cannot be required to prove a negative.
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