Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Customs Broker due diligence requires prescribed KYC, not detecting misdeclarations discoverable only through physical examination, defeating licence ...
E-filing system failure permits exclusion of affected time in insolvency appeals, preventing tribunal technology defects from defeating timely filings...
Undisclosed-income additions for penny-stock transactions cannot rest solely on Investigation Wing information where recorded share purchases and sales show a loss and no substantive or corroborative evidence establishes unaccounted income. The ITAT therefore deleted that addition. It also deleted an estimated-profit addition for alleged share dealings: the taxpayer denied the transactions, and estimating profit from alleged turnover without substantive supporting material amounted to assumption, presumption and speculation. Both additions failed for lack of substantive and corroborative evidence.
Undisclosed-income additions for penny-stock transactions cannot rest solely on Investigation Wing information where recorded share purchases and sales show a loss and no substantive or corroborative evidence establishes unaccounted income. The ITAT therefore deleted that addition. It also deleted an estimated-profit addition for alleged share dealings: the taxpayer denied the transactions, and estimating profit from alleged turnover without substantive supporting material amounted to assumption, presumption and speculation. Both additions failed for lack of substantive and corroborative evidence.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
