Brokerage commission benchmarking and investment advisory comparability depend on functional differences, economic circumstances and the services prov...
Unexplained cash credits require the assessee to establish the creditor's identity and capacity and the genuineness of the transaction before the burden shifts to the Revenue. Corporate records, tax filings, banking transactions and repayment alone may not establish genuineness where surrounding circumstances indicate accommodation entries; estimated commission may also be added. Interest is deductible only where capital is genuinely borrowed and used for business, and bank payments or tax deducted at source are not conclusive. For reassessment, material must have a live link to a prima facie belief that income escaped assessment; its sufficiency to sustain an addition is not tested at reopening. Statutory approval is not defective merely because satisfaction is expressed briefly.
Unexplained cash credits require the assessee to establish the creditor's identity and capacity and the genuineness of the transaction before the burden shifts to the Revenue. Corporate records, tax filings, banking transactions and repayment alone may not establish genuineness where surrounding circumstances indicate accommodation entries; estimated commission may also be added. Interest is deductible only where capital is genuinely borrowed and used for business, and bank payments or tax deducted at source are not conclusive. For reassessment, material must have a live link to a prima facie belief that income escaped assessment; its sufficiency to sustain an addition is not tested at reopening. Statutory approval is not defective merely because satisfaction is expressed briefly.
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