Foundational assessment satisfaction is essential before initiating penalty for cash receipt of immovable-property sale consideration under section 27...
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...
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.
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