Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
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Cash gifts from close relatives cannot be treated as unexplained credits where gift deeds, confirmations, tax returns, financial statements and responses to statutory notices establish donor identity, transaction genuineness and basic creditworthiness. The assessee's initial burden is then discharged, and any enquiry into donors' actual funding sources belongs in their own assessments unless a statute provides otherwise. Earlier adverse donor assessments or doubts about financial capacity cannot alone establish that gifted funds were the assessee's own money. On these principles, the cash-gift addition and consequential special-rate tax treatment were deleted.
Cash gifts from close relatives cannot be treated as unexplained credits where gift deeds, confirmations, tax returns, financial statements and responses to statutory notices establish donor identity, transaction genuineness and basic creditworthiness. The assessee's initial burden is then discharged, and any enquiry into donors' actual funding sources belongs in their own assessments unless a statute provides otherwise. Earlier adverse donor assessments or doubts about financial capacity cannot alone establish that gifted funds were the assessee's own money. On these principles, the cash-gift addition and consequential special-rate tax treatment were deleted.
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