Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
Section 7 admission requires established financial debt and default, not precise interest quantification, while post-suspension defaults remain action...
Assessment u/s 153A - Addition u/s 68 - bogus LTCG - penny Stocks - whether documents found during the course of search were of incriminating nature? - The tribunal noted that the documents seized (share certificates and contract notes), alleged to be incriminating, corroborated the disclosed transactions of the purchase and sale of shares, thus not qualifying as 'incriminating evidence' discovered during the search. - The ITAT also observed that reliance on statements recorded outside the assessee's search operation, particularly from a broker, cannot augment the material found during the search to categorize it as incriminating. - Additions deleted.
Assessment u/s 153A - Addition u/s 68 - bogus LTCG - penny Stocks - whether documents found during the course of search were of incriminating nature? - The tribunal noted that the documents seized (share certificates and contract notes), alleged to be incriminating, corroborated the disclosed transactions of the purchase and sale of shares, thus not qualifying as 'incriminating evidence' discovered during the search. - The ITAT also observed that reliance on statements recorded outside the assessee's search operation, particularly from a broker, cannot augment the material found during the search to categorize it as incriminating. - Additions deleted.
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