SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
