Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
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ITAT denied LTCG exemption u/s 10(38) and confirmed addition u/s 68 against the assessee. The tribunal observed no prior investment history, lack of substantive transaction evidence, and suspicious share trading pattern. Despite opportunities to validate transactions, the assessee failed to provide credible documentation. The tribunal referenced precedent involving penny stock transactions and found no genuine sale evidence beyond broker contract notes. The absence of verifiable transaction details and inconsistent trading behavior led to dismissal of the assessee's appeal, upholding the revenue's assessment and rejecting claimed long-term capital gains exemption.
ITAT denied LTCG exemption u/s 10(38) and confirmed addition u/s 68 against the assessee. The tribunal observed no prior investment history, lack of substantive transaction evidence, and suspicious share trading pattern. Despite opportunities to validate transactions, the assessee failed to provide credible documentation. The tribunal referenced precedent involving penny stock transactions and found no genuine sale evidence beyond broker contract notes. The absence of verifiable transaction details and inconsistent trading behavior led to dismissal of the assessee's appeal, upholding the revenue's assessment and rejecting claimed long-term capital gains exemption.
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