Unverified Insight Portal Information Cannot Justify Reassessment Without a Verified Taxpayer-Specific Income-Escape Nexus or Demonstrated Application...
Assessing Officer jurisdiction after statutory transfer invalidates reassessment notices issued by transferor officers and nullifies resulting proceed...
Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
ITAT dismissed revenue's appeal concerning disputed long-term capital gains from penny stock transactions. While AO treated gains as unexplained cash credits under Section 68, assessee successfully demonstrated transaction legitimacy through comprehensive documentation including bank statements, contract notes, demat records and audited financials. Revenue failed to establish price manipulation or collusion with counterparties through direct evidence. Mere suspicion of accommodation entries in penny stocks insufficient to sustain addition without concrete proof rebutting assessee's evidence. CIT(A)'s deletion of addition upheld as assessee discharged onus of proving genuine nature of LTCG while revenue relied on generalized allegations without substantive material establishing non-genuineness.
ITAT dismissed revenue's appeal concerning disputed long-term capital gains from penny stock transactions. While AO treated gains as unexplained cash credits under Section 68, assessee successfully demonstrated transaction legitimacy through comprehensive documentation including bank statements, contract notes, demat records and audited financials. Revenue failed to establish price manipulation or collusion with counterparties through direct evidence. Mere suspicion of accommodation entries in penny stocks insufficient to sustain addition without concrete proof rebutting assessee's evidence. CIT(A)'s deletion of addition upheld as assessee discharged onus of proving genuine nature of LTCG while revenue relied on generalized allegations without substantive material establishing non-genuineness.
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