Fake-invoice penalties remain available where taxpayer admissions and records establish unsupported input tax credit claims and false GST documentatio...
Works contract classification applies to permanently installed fire-protection systems, while earthwork and obsolete IGST concessions remain unavailab...
Professional fee recovery for GST refund representation succeeds where direct engagement, fee acknowledgement, and authority are established despite c...
Transfer pricing of intra-group support services requires prescribed benchmarking; unsupported nil valuation and alternate business-expense disallowan...
Diversion of income by overriding title arose where a collaboration agreement, banking records, ledger accounts and supporting material established the collaborator's entitlement to a share of flat-sale proceeds. That share did not accrue as the assessee's income because the agreement imposed an overriding obligation; procedural non-compliance, stamp-paper objections, lack of witnesses or doubts about expertise did not establish a fictitious income-diversion device. The resulting addition was deleted. Land acquisition cost could not be disallowed on the basis that it was absent from the books, since the books recorded the land and the purchase deed substantiated acquisition. The unexplained-source inference and related disallowance were deleted.
Diversion of income by overriding title arose where a collaboration agreement, banking records, ledger accounts and supporting material established the collaborator's entitlement to a share of flat-sale proceeds. That share did not accrue as the assessee's income because the agreement imposed an overriding obligation; procedural non-compliance, stamp-paper objections, lack of witnesses or doubts about expertise did not establish a fictitious income-diversion device. The resulting addition was deleted. Land acquisition cost could not be disallowed on the basis that it was absent from the books, since the books recorded the land and the purchase deed substantiated acquisition. The unexplained-source inference and related disallowance were deleted.
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