SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
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Determination of sale consideration - reliance on photocopy of the alleged agreement to sell - The High Court scrutinized the circumstances surrounding the photocopy of the agreement to sell. It noted that the original document was not produced, and there was no other evidence to corroborate the details mentioned in the photocopy. Therefore, the court concluded that the photocopy alone could not serve as a valid basis for making additions to the assessee's income. - The court emphasized that the burden of proving the authenticity of the photocopy rested with the Revenue, especially since the entire case relied solely on it.
Determination of sale consideration - reliance on photocopy of the alleged agreement to sell - The High Court scrutinized the circumstances surrounding the photocopy of the agreement to sell. It noted that the original document was not produced, and there was no other evidence to corroborate the details mentioned in the photocopy. Therefore, the court concluded that the photocopy alone could not serve as a valid basis for making additions to the assessee's income. - The court emphasized that the burden of proving the authenticity of the photocopy rested with the Revenue, especially since the entire case relied solely on it.
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