Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
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...
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The ITAT ruled in favor of the assessee, allowing the loss incurred in stock option transactions. The Assessing Officer (AO) had disallowed the loss, alleging that the options were sold at unreasonably low prices, even below their intrinsic value. However, the ITAT observed that the AO's conclusion was based solely on conjecture without any corroborative evidence. The assessee had provided contract notes and ledger accounts proving the transactions were conducted through the Bombay Stock Exchange (BSE). Despite this, the revenue authorities neither rebutted nor challenged the authenticity of the submitted documents. The assessee discharged their burden of proof, and the onus shifted to the revenue authorities, who failed to bring any comparative data or evidence to substantiate their claims. Consequently, the ITAT set aside the impugned appellate order and deleted the addition, deciding in favor of the assessee.
The ITAT ruled in favor of the assessee, allowing the loss incurred in stock option transactions. The Assessing Officer (AO) had disallowed the loss, alleging that the options were sold at unreasonably low prices, even below their intrinsic value. However, the ITAT observed that the AO's conclusion was based solely on conjecture without any corroborative evidence. The assessee had provided contract notes and ledger accounts proving the transactions were conducted through the Bombay Stock Exchange (BSE). Despite this, the revenue authorities neither rebutted nor challenged the authenticity of the submitted documents. The assessee discharged their burden of proof, and the onus shifted to the revenue authorities, who failed to bring any comparative data or evidence to substantiate their claims. Consequently, the ITAT set aside the impugned appellate order and deleted the addition, deciding in favor of the assessee.
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