Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes...
Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
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Section 69 applies only to investments not recorded in the assessee's books of account. Immovable properties recorded in the firm's regular books, together with corresponding identifiable partners' capital contributions, cannot be treated as unexplained investments where the books have not been found defective or rejected. Concerns about an individual partner's financial capacity must be examined in that partner's assessment and do not, by themselves, make the firm's recorded investment unexplained. Principles applicable to unexplained cash credits do not govern recorded investments under section 69. The addition for unexplained investment was therefore deleted, while the reassessment challenge was left academic.
Section 69 applies only to investments not recorded in the assessee's books of account. Immovable properties recorded in the firm's regular books, together with corresponding identifiable partners' capital contributions, cannot be treated as unexplained investments where the books have not been found defective or rejected. Concerns about an individual partner's financial capacity must be examined in that partner's assessment and do not, by themselves, make the firm's recorded investment unexplained. Principles applicable to unexplained cash credits do not govern recorded investments under section 69. The addition for unexplained investment was therefore deleted, while the reassessment challenge was left academic.
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