Tax collection at source on purchases removes duplicate withholding obligation, while trade-creditor evidence requires verification before unexplained...
Transfer-pricing comparability requires material turnover effects; adjustments must cover only associated-enterprise transactions and exclude abnormal...
Genuineness of dematerialised equity-share transactions supporting a long-term capital-gains claim depends on documentary evidence, banking-channel payments and identifiable transaction records. Where taxpayers produce such evidence, an allegation that share-sale proceeds constitute unexplained cash credit requires specific defects or rebuttal of the material. An alleged commission expenditure linked solely to the asserted bogus share-sale proceeds is consequential and cannot independently sustain disallowance where the underlying allegation fails.
Genuineness of dematerialised equity-share transactions supporting a long-term capital-gains claim depends on documentary evidence, banking-channel payments and identifiable transaction records. Where taxpayers produce such evidence, an allegation that share-sale proceeds constitute unexplained cash credit requires specific defects or rebuttal of the material. An alleged commission expenditure linked solely to the asserted bogus share-sale proceeds is consequential and cannot independently sustain disallowance where the underlying allegation fails.
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