Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
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 4888 
