Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from...
Transfer-pricing benchmarking confines adjustments to associated-enterprise transactions and integrates delayed receivables through TNMM working-capit...
Medical relief status protects government-contracted mobile healthcare from commercial classification, while provisional registration cancellation req...
Charitable registration cancellation requires proof that educational activities abandoned their objects; incidental receipts and retained surplus are ...
Uncorroborated electronic records cannot alone support additions for unexplained investments, expenditure, interest, sales or debtor balances unless independent evidence establishes their nexus with the assessee and the recorded transactions. Excel worksheets, payment sheets and electronic debtor data containing inconsistencies, without supplier or debtor verification, books, invoices, banking records or other supporting material, failed this standard; the related additions were deleted. WeChat diary figures were accepted only to the extent actually recorded, with gross profit estimated thereon, because no evidence justified applying a multiplier. Cash-rent expenditure was disallowed for want of receipts, ledger entries, landlord confirmation or payment proof, and unexplained stock investment was sustained because the stock difference remained unreconciled.
Uncorroborated electronic records cannot alone support additions for unexplained investments, expenditure, interest, sales or debtor balances unless independent evidence establishes their nexus with the assessee and the recorded transactions. Excel worksheets, payment sheets and electronic debtor data containing inconsistencies, without supplier or debtor verification, books, invoices, banking records or other supporting material, failed this standard; the related additions were deleted. WeChat diary figures were accepted only to the extent actually recorded, with gross profit estimated thereon, because no evidence justified applying a multiplier. Cash-rent expenditure was disallowed for want of receipts, ledger entries, landlord confirmation or payment proof, and unexplained stock investment was sustained because the stock difference remained unreconciled.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4884 
