Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
Preventive suspension requires an immediate continuing threat and cannot become indefinite without inquiry, fresh evidence, or proportionate safeguard...
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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