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...
Penny-stock long-term capital-gain claims may fail despite demat, exchange, banking and securities-transaction-tax records where abnormal price movement, operator material and layered purchaser funding establish accommodation entries under the test of human probabilities; related commission additions may consequently stand. Exempt-income expenditure disallowance requires examination of all exempt income, including claimed long-term gains, and may require recomputation. A loose-paper entry cannot be added to a person not named or supported by material, though it may be considered in the attributable family member's assessment. For unsecured loans, established identity alone does not prove creditworthiness or genuineness. Confirmed foreign-account sources can defeat additions absent contrary material. Concealment penalties are invalid where notice does not specify the applicable charge.
Penny-stock long-term capital-gain claims may fail despite demat, exchange, banking and securities-transaction-tax records where abnormal price movement, operator material and layered purchaser funding establish accommodation entries under the test of human probabilities; related commission additions may consequently stand. Exempt-income expenditure disallowance requires examination of all exempt income, including claimed long-term gains, and may require recomputation. A loose-paper entry cannot be added to a person not named or supported by material, though it may be considered in the attributable family member's assessment. For unsecured loans, established identity alone does not prove creditworthiness or genuineness. Confirmed foreign-account sources can defeat additions absent contrary material. Concealment penalties are invalid where notice does not specify the applicable charge.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
