Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
Non-proving identity, creditworthiness, and genuineness of share premium received cannot be treated as unexplained income if sufficient documentary evidence is provided. Once a company proves existence and authenticity of shareholders, it discharges burden u/s 68. Share premium is a matter of business prerogative, and revenue cannot question its quantum without evidence of collusion or mala fide intent. If an assessee sufficiently establishes identity, creditworthiness, and genuineness of share capital transaction, addition u/s 68 as unexplained cash credit is unsustainable and should be deleted by the Assessing Officer.
Non-proving identity, creditworthiness, and genuineness of share premium received cannot be treated as unexplained income if sufficient documentary evidence is provided. Once a company proves existence and authenticity of shareholders, it discharges burden u/s 68. Share premium is a matter of business prerogative, and revenue cannot question its quantum without evidence of collusion or mala fide intent. If an assessee sufficiently establishes identity, creditworthiness, and genuineness of share capital transaction, addition u/s 68 as unexplained cash credit is unsustainable and should be deleted by the Assessing Officer.
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