Concessional corporate tax option under section 115BAA survives procedural documentary lapses when statutory compliance and earlier exercise are estab...
Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Unrealised mark-to-market gains on a forward commodity derivative were held not taxable before actual accrual or maturity because income must have really accrued to be brought to tax under mercantile accounting. Applying Woodward Governor and Godhra Electricity, the Court held that fluctuating gains and losses on a forward contract remain notional until expiry, so anticipated gains reflected in accounts do not lose their unrealised character merely due to accounting treatment. The deletion of the addition was upheld, with the clarification that tax consequences on maturity would follow in accordance with law.
Unrealised mark-to-market gains on a forward commodity derivative were held not taxable before actual accrual or maturity because income must have really accrued to be brought to tax under mercantile accounting. Applying Woodward Governor and Godhra Electricity, the Court held that fluctuating gains and losses on a forward contract remain notional until expiry, so anticipated gains reflected in accounts do not lose their unrealised character merely due to accounting treatment. The deletion of the addition was upheld, with the clarification that tax consequences on maturity would follow in accordance with law.
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