Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
Gifted unlisted shares taxed on receipt under section 56(2)(x) retain their character as assets acquired by gift for determining the holding period. The previous owner's holding period is included, so a subsequent transfer may produce long-term capital gains. However, section 49(4) separately fixes the donee's cost at the value previously taxed under section 56(2)(x); it does not carry over the prior owner's cost. Consequently, indexation of that deemed cost begins only in the financial year in which it was taxed, not in an earlier ownership period.
Gifted unlisted shares taxed on receipt under section 56(2)(x) retain their character as assets acquired by gift for determining the holding period. The previous owner's holding period is included, so a subsequent transfer may produce long-term capital gains. However, section 49(4) separately fixes the donee's cost at the value previously taxed under section 56(2)(x); it does not carry over the prior owner's cost. Consequently, indexation of that deemed cost begins only in the financial year in which it was taxed, not in an earlier ownership period.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
