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...
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 
