Departmental appeal limitation after call-book recall preserves original filing, while documented correlation supports SAD refund on imported granules...
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...
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 4886 
