Reassessment sanction under extended limitation required approval from the competent specified authority, invalidating proceedings approved by an inco...
Internal CUP benchmarking for fixed-rate Masala Bonds prevails over floating external comparables, eliminating the related transfer-pricing adjustment...
Jurisdictional validity of revision notices: incorrect official capacity and mere change of opinion invalidate revision of property income assessments...
Bogus-purchase additions are limited to embedded profit where corresponding sales are accepted, while accommodation-entry information can support reas...
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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.
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