Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Bogus purchase additions under section 69C were discussed in the context of whether the assessee had discharged the burden of proving genuineness; the note states that purchase invoices, supplier ledgers, transport receipts, banking records and regular books supported the transactions, and that a mere reversal of input tax credit did not by itself establish non-genuine purchases. It also addresses reassessment under section 148, stating that notice and the section 148A(d) order were not in accordance with law where the reopening was based on DGGI/Insight information, the material was not supplied to the assessee, and no independent application of mind was shown. The addition and reopening are described as unsustainable on those facts.
Bogus purchase additions under section 69C were discussed in the context of whether the assessee had discharged the burden of proving genuineness; the note states that purchase invoices, supplier ledgers, transport receipts, banking records and regular books supported the transactions, and that a mere reversal of input tax credit did not by itself establish non-genuine purchases. It also addresses reassessment under section 148, stating that notice and the section 148A(d) order were not in accordance with law where the reopening was based on DGGI/Insight information, the material was not supplied to the assessee, and no independent application of mind was shown. The addition and reopening are described as unsustainable on those facts.
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