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...
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Reassessment jurisdiction requires recorded reasons to show an independently formed prima facie belief and a rational, live nexus between investigation material and income alleged to have escaped assessment. Information understood as relating to bogus purchases cannot support an assessment of the same amounts as unexplained unsecured loans without transaction-specific application of mind; subsequent findings cannot cure defects in the recorded reasons. For unsecured loans, lender confirmations, banking records, tax documents and affidavits may discharge the initial burden on identity, transaction trail and source. A preceding equivalent bank credit alone does not establish an accommodation entry without verification and cogent rebuttal of the disclosed source.
Reassessment jurisdiction requires recorded reasons to show an independently formed prima facie belief and a rational, live nexus between investigation material and income alleged to have escaped assessment. Information understood as relating to bogus purchases cannot support an assessment of the same amounts as unexplained unsecured loans without transaction-specific application of mind; subsequent findings cannot cure defects in the recorded reasons. For unsecured loans, lender confirmations, banking records, tax documents and affidavits may discharge the initial burden on identity, transaction trail and source. A preceding equivalent bank credit alone does not establish an accommodation entry without verification and cogent rebuttal of the disclosed source.
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TaxTMI 
TaxTMI 
