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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Assessee successfully met the initial burden to prove identity, creditworthiness and genuineness of unexplained cash credits from an investor company; the AO failed to make independent enquiries or produce contrary material, so additions under section 68 were deleted. Assessee's claim of agricultural income, previously accepted in an earlier year and supported by ownership of agricultural land, was held genuine and the related addition was deleted. Assessee also satisfied factual conditions for long term capital gains by acquiring shares through preferential allotment, paying by account payee cheques, holding for requisite period and selling on a recognised stock exchange with STT paid; denial of section 10(38) benefit was reversed.
Assessee successfully met the initial burden to prove identity, creditworthiness and genuineness of unexplained cash credits from an investor company; the AO failed to make independent enquiries or produce contrary material, so additions under section 68 were deleted. Assessee's claim of agricultural income, previously accepted in an earlier year and supported by ownership of agricultural land, was held genuine and the related addition was deleted. Assessee also satisfied factual conditions for long term capital gains by acquiring shares through preferential allotment, paying by account payee cheques, holding for requisite period and selling on a recognised stock exchange with STT paid; denial of section 10(38) benefit was reversed.
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