Foundational assessment satisfaction is essential before initiating penalty for cash receipt of immovable-property sale consideration under section 27...
Tax collection at source on purchases removes duplicate withholding obligation, while trade-creditor evidence requires verification before unexplained...
Transfer-pricing comparability requires material turnover effects; adjustments must cover only associated-enterprise transactions and exclude abnormal...
Reassessment initiated on departmental information flagged through the Insight Portal remains valid where the Assessing Officer independently confronts the taxpayer with the information, considers the response, passes an order under section 148A(d), and then issues notice under section 148. Such information may provide a starting point for enquiry without constituting borrowed satisfaction. However, sale proceeds from shares cannot be treated as unexplained accommodation entries merely on investigation allegations or suspicion where broker transactions, demat records, contract notes and banking channels remain undisputed, and no independent corroboration, cash trail, or link to an entry provider is established. The reassessment survived, but the share-sale addition was deleted.
Reassessment initiated on departmental information flagged through the Insight Portal remains valid where the Assessing Officer independently confronts the taxpayer with the information, considers the response, passes an order under section 148A(d), and then issues notice under section 148. Such information may provide a starting point for enquiry without constituting borrowed satisfaction. However, sale proceeds from shares cannot be treated as unexplained accommodation entries merely on investigation allegations or suspicion where broker transactions, demat records, contract notes and banking channels remain undisputed, and no independent corroboration, cash trail, or link to an entry provider is established. The reassessment survived, but the share-sale addition was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
