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...
Non-compete fee received is a capital receipt not liable to tax. Surplus on cancellation of debentures issued for capital expenditure is not taxable. Premium paid on redemption of debentures is allowable expenditure. Payment for acquisition of a going concern is capital expenditure. Cost of improvement to be allowed indexation. Cost of acquisition of amalgamated business to be taken as cost to previous owner. Claim of capital loss on surrender of land to DDA not entertained as it requires verification of facts.
Non-compete fee received is a capital receipt not liable to tax. Surplus on cancellation of debentures issued for capital expenditure is not taxable. Premium paid on redemption of debentures is allowable expenditure. Payment for acquisition of a going concern is capital expenditure. Cost of improvement to be allowed indexation. Cost of acquisition of amalgamated business to be taken as cost to previous owner. Claim of capital loss on surrender of land to DDA not entertained as it requires verification of facts.
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