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...
Historical wealth-tax records, valuation reports and family-distribution evidence can substantiate ancestral and self-owned jewellery; non-filing of later wealth-tax returns, without evidence of disposal, does not establish that prior holdings were sold. Accordingly, jewellery disclosed in Schedule AL could not be treated as unexplained merely because original purchase bills were unavailable. Brokerage paid to a Hindu undivided family is not deductible as investment cost for capital-gains exemption where no family fund or asset generated the income and its Karta or coparcener was separately paid for the same personal services. Recipient confirmation or taxability does not establish deductibility; the brokerage disallowance remained sustainable.
Historical wealth-tax records, valuation reports and family-distribution evidence can substantiate ancestral and self-owned jewellery; non-filing of later wealth-tax returns, without evidence of disposal, does not establish that prior holdings were sold. Accordingly, jewellery disclosed in Schedule AL could not be treated as unexplained merely because original purchase bills were unavailable. Brokerage paid to a Hindu undivided family is not deductible as investment cost for capital-gains exemption where no family fund or asset generated the income and its Karta or coparcener was separately paid for the same personal services. Recipient confirmation or taxability does not establish deductibility; the brokerage disallowance remained sustainable.
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