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...
Natural justice in insolvency-professional discipline requires disclosed material; notices based on extraneous material and ignored defences are vitia...
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Corporate guarantee liability becomes deductible in the previous year in which settlement fixes and crystallises the obligation. Where the settlement occurred in the previous year relevant to Assessment Year 1998-99, subsequent consent terms merely implemented and discharged the already determined liability; they did not defer the year of deduction. The resulting business-loss deduction was therefore allowable for Assessment Year 1998-99.
Corporate guarantee liability becomes deductible in the previous year in which settlement fixes and crystallises the obligation. Where the settlement occurred in the previous year relevant to Assessment Year 1998-99, subsequent consent terms merely implemented and discharged the already determined liability; they did not defer the year of deduction. The resulting business-loss deduction was therefore allowable for Assessment Year 1998-99.
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