Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
The ITAT held that u/s 10(38), only long term capital gain from sale of shares/securities is exempt, not the entire source. Citing Royal Calcutta Turf Club case, it ruled that if a source is not excluded from charging section, only specific income is exempt. Loss from shares with STT can offset long term capital gain from unlisted shares. AO directed to allow set off. The decision emphasizes strict interpretation of law when only specific income is exempted.
The ITAT held that u/s 10(38), only long term capital gain from sale of shares/securities is exempt, not the entire source. Citing Royal Calcutta Turf Club case, it ruled that if a source is not excluded from charging section, only specific income is exempt. Loss from shares with STT can offset long term capital gain from unlisted shares. AO directed to allow set off. The decision emphasizes strict interpretation of law when only specific income is exempted.
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