Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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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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