Centralised assessment transfers after searches coordinate connected investigations without finally determining the assessee's tax liability or assess...
Unsigned third-party records cannot establish on-money payments without corroboration and cross-examination, requiring deletion of the related additio...
Gross principal cash movements routed through an Angadia network were not taxable as the assessee's unexplained money where the accepted business model showed only a facilitation role and no material established ownership of the funds or corresponding asset accretion. Applying the real-income principle, taxability was confined to embedded commission income, resulting in rejection of the Revenue's challenge to deletion of principal additions. Commission on unaccounted turnover was estimated at 0.30%, rather than 2%, after credit for commission already assessed, because of the business's low-margin nature. The commission income was taxable at normal rates rather than under section 115BBE.
Gross principal cash movements routed through an Angadia network were not taxable as the assessee's unexplained money where the accepted business model showed only a facilitation role and no material established ownership of the funds or corresponding asset accretion. Applying the real-income principle, taxability was confined to embedded commission income, resulting in rejection of the Revenue's challenge to deletion of principal additions. Commission on unaccounted turnover was estimated at 0.30%, rather than 2%, after credit for commission already assessed, because of the business's low-margin nature. The commission income was taxable at normal rates rather than under section 115BBE.
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