Separate speaking orders on reopening objections are mandatory; deciding them within reassessment invalidates jurisdiction and precludes revival of st...
Compulsorily convertible debentures remain debt before conversion, preventing transfer-pricing and interest-deduction disallowances on the stated fact...
Stock-in-trade transfer taxability follows possession and consideration, not later conveyance registration, limiting deemed-value provisions to the ac...
Investigation material linking three loan creditors to accommodation-entry providers, supported by admissions concerning management of bank accounts and income-tax files, established a sufficient nexus for reassessment; the challenge to reopening failed. Confirmations and bank records showing full repayment in the following financial year, together with no corresponding addition for loans from the same creditors in the succeeding year, meant the loans could not be treated as accommodation entries. The Tribunal deleted the bogus-loan addition, and the consequential unexplained-expenditure addition did not survive; the appeal was partly allowed.
Investigation material linking three loan creditors to accommodation-entry providers, supported by admissions concerning management of bank accounts and income-tax files, established a sufficient nexus for reassessment; the challenge to reopening failed. Confirmations and bank records showing full repayment in the following financial year, together with no corresponding addition for loans from the same creditors in the succeeding year, meant the loans could not be treated as accommodation entries. The Tribunal deleted the bogus-loan addition, and the consequential unexplained-expenditure addition did not survive; the appeal was partly allowed.
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TaxTMI 
TaxTMI 
