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...
Section 68 treatment of unsecured loans requires lender non-compliance with notices to be assessed alongside other record material; non-compliance alone does not establish unexplained cash credit. A credit relating to an earlier financial year falls outside the relevant previous year, and bank-channel receipt and repayment supported the other loan; the unsecured-loan addition was deleted. Flat-sale consideration claimed as already taxed requires verification against books and assessment records, so that issue remains for assessment verification. Corpus-fund and society deposits cannot be treated as unexplained or yield notional interest merely because the society was unformed or funds were retained; however, purchaser-wise evidence must be examined before their character and source are determined.
Section 68 treatment of unsecured loans requires lender non-compliance with notices to be assessed alongside other record material; non-compliance alone does not establish unexplained cash credit. A credit relating to an earlier financial year falls outside the relevant previous year, and bank-channel receipt and repayment supported the other loan; the unsecured-loan addition was deleted. Flat-sale consideration claimed as already taxed requires verification against books and assessment records, so that issue remains for assessment verification. Corpus-fund and society deposits cannot be treated as unexplained or yield notional interest merely because the society was unformed or funds were retained; however, purchaser-wise evidence must be examined before their character and source are determined.
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