Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Genuine share transactions supported by banking records and transfer documents cannot be disregarded merely because they generate a tax loss. The discussion identifies that no adverse material established an artificial or pre-conceived arrangement, and the sale price exceeded the price at which another related purchaser had acquired the shares. On these facts, the short-term capital loss from sale of unlisted shares to a spouse was not treated as a colourable device, and its disallowance was deleted.
Genuine share transactions supported by banking records and transfer documents cannot be disregarded merely because they generate a tax loss. The discussion identifies that no adverse material established an artificial or pre-conceived arrangement, and the sale price exceeded the price at which another related purchaser had acquired the shares. On these facts, the short-term capital loss from sale of unlisted shares to a spouse was not treated as a colourable device, and its disallowance was deleted.
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