Internal CUP benchmarking for fixed-rate Masala Bonds prevails over floating external comparables, eliminating the related transfer-pricing adjustment...
Jurisdictional validity of revision notices: incorrect official capacity and mere change of opinion invalidate revision of property income assessments...
Bogus-purchase additions are limited to embedded profit where corresponding sales are accepted, while accommodation-entry information can support reas...
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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