SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Reassessment proceedings require the Assessing Officer to furnish recorded reasons on the taxpayer's request and dispose of objections before continuing the reassessment; non-compliance renders the reassessment unsustainable. For alleged bogus long-term capital gains, contemporaneous banking and demat records, contract notes, securities transaction tax evidence, and proof of share acquisition and sale can establish transaction genuineness. General investigation material or suspicion, without cogent evidence linking the taxpayer to accommodation entries or cash payments to an entry provider, cannot displace that evidence. Additions for unexplained share-sale proceeds and consequential alleged commission were deleted.
Reassessment proceedings require the Assessing Officer to furnish recorded reasons on the taxpayer's request and dispose of objections before continuing the reassessment; non-compliance renders the reassessment unsustainable. For alleged bogus long-term capital gains, contemporaneous banking and demat records, contract notes, securities transaction tax evidence, and proof of share acquisition and sale can establish transaction genuineness. General investigation material or suspicion, without cogent evidence linking the taxpayer to accommodation entries or cash payments to an entry provider, cannot displace that evidence. Additions for unexplained share-sale proceeds and consequential alleged commission were deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
