Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
ITAT ruled that the appellant failed to substantiate the genuineness of purchase transactions involving shell companies. Despite presenting bank statements and tax challans, the tribunal found the documentary evidence insufficient to prove legitimate business transactions. The AO's findings of non-existent suppliers and lack of cross-examination were upheld. Consequently, the tribunal allowed a 12.5% disallowance of unverified purchase amounts, effectively rejecting the appellant's appeal grounds and maintaining the original assessment order's core findings regarding tax evasion through grey market purchases.
ITAT ruled that the appellant failed to substantiate the genuineness of purchase transactions involving shell companies. Despite presenting bank statements and tax challans, the tribunal found the documentary evidence insufficient to prove legitimate business transactions. The AO's findings of non-existent suppliers and lack of cross-examination were upheld. Consequently, the tribunal allowed a 12.5% disallowance of unverified purchase amounts, effectively rejecting the appellant's appeal grounds and maintaining the original assessment order's core findings regarding tax evasion through grey market purchases.
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