Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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...
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ITAT upheld the AO and CIT(A) in confirming an addition under s. 68, finding the assessee's credit entries and claimed exempt LTCG were sham and not bona fide. The Tribunal held the assessee failed to discharge the statutory onus to prove genuineness of share-sale and credit transactions; surrounding circumstances, non-disclosure in the original return, unexplained share acquisitions, and evidential materials produced by the Revenue established the transactions as bogus. Consequently the reassessment/addition was sustained and the appeal dismissed, with the Tribunal treating the LTCG claim as a façade concealing the true nature of the impugned credits.
ITAT upheld the AO and CIT(A) in confirming an addition under s. 68, finding the assessee's credit entries and claimed exempt LTCG were sham and not bona fide. The Tribunal held the assessee failed to discharge the statutory onus to prove genuineness of share-sale and credit transactions; surrounding circumstances, non-disclosure in the original return, unexplained share acquisitions, and evidential materials produced by the Revenue established the transactions as bogus. Consequently the reassessment/addition was sustained and the appeal dismissed, with the Tribunal treating the LTCG claim as a façade concealing the true nature of the impugned credits.
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