Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
Reassessment proceedings in search-related group cases were upheld as valid, with initiation and notices sustained following coordinate-bench precedent and applicable procedural provisions. For receipts characterised as unaccounted 'on money', only the profit element is taxable and the appropriate benchmark rate for estimation was fixed at 10%, reducing higher departmental estimates. Unaccounted profit arising on sale of immovable property must be recognised and taxed in the year of actual sale (execution/registration of the sale deed) where risks and rewards transfer; ICDS III was held inapplicable to the assessee. Confirmed estimated unaccounted profit was permitted to be set off (telescoped) against additions for alleged advances/expenses, avoiding double taxation.
Reassessment proceedings in search-related group cases were upheld as valid, with initiation and notices sustained following coordinate-bench precedent and applicable procedural provisions. For receipts characterised as unaccounted 'on money', only the profit element is taxable and the appropriate benchmark rate for estimation was fixed at 10%, reducing higher departmental estimates. Unaccounted profit arising on sale of immovable property must be recognised and taxed in the year of actual sale (execution/registration of the sale deed) where risks and rewards transfer; ICDS III was held inapplicable to the assessee. Confirmed estimated unaccounted profit was permitted to be set off (telescoped) against additions for alleged advances/expenses, avoiding double taxation.
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