Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
Bogus long-term capital gains additions on listed shares under section 68 cannot be sustained on suspicion alone where the assessee produces purchase records, demat statements, stock exchange sale documents and banking evidence, and the Revenue brings no specific rebuttal. The Tribunal held that general investigation inputs and allegations of penny stock accommodation entries do not displace documentary proof unless there is cogent material linking the assessee to a sham or manipulated transaction. On similar facts, including decisions involving the same scrip, the CIT(A)'s deletion of the addition was upheld and the Revenue's challenge failed.
Bogus long-term capital gains additions on listed shares under section 68 cannot be sustained on suspicion alone where the assessee produces purchase records, demat statements, stock exchange sale documents and banking evidence, and the Revenue brings no specific rebuttal. The Tribunal held that general investigation inputs and allegations of penny stock accommodation entries do not displace documentary proof unless there is cogent material linking the assessee to a sham or manipulated transaction. On similar facts, including decisions involving the same scrip, the CIT(A)'s deletion of the addition was upheld and the Revenue's challenge failed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4807 
Join Channel 
