Capital Gain Deductibility: proportionate IPO and PMS expenses held allowable against capital gains where netting and nexus to transfer are establishe...
Admissibility of Documentary Evidence: appellate authority may admit self explanatory documents on first production and uphold deletion of unexplained...
Search warrant substantially complied with statutory requirements despite listing bank account before assessee name; search validity sustained and grounds challenging panchnama dismissed. Assessment for the year of search was correctly framed under the ordinary assessment provision while assessments for the six preceding years fall under special post-search assessment procedure, so framing under the ordinary provision for the search year is upheld. Additions based solely on a definition provision were reversed because a charging provision is required to create tax liability; the appellate authority's recharacterisation as business income was rejected since no factual or commercial basis established that the taxpayer carried on such business.
Search warrant substantially complied with statutory requirements despite listing bank account before assessee name; search validity sustained and grounds challenging panchnama dismissed. Assessment for the year of search was correctly framed under the ordinary assessment provision while assessments for the six preceding years fall under special post-search assessment procedure, so framing under the ordinary provision for the search year is upheld. Additions based solely on a definition provision were reversed because a charging provision is required to create tax liability; the appellate authority's recharacterisation as business income was rejected since no factual or commercial basis established that the taxpayer carried on such business.
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