Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
Forensic extraction from a director's mobile phone was treated as admissible without a separate section 138C certificate because the phone was recovered under panchnama and examined in context with the surrounding record. Rule 12 permitted rejection of declared transaction value where reasonable doubt arose from the director's statement and parallel invoices showing higher values, so re-determination of assessable value was upheld. Misdeclaration of value attracted confiscation under section 111(m), and the same undisclosed invoices justified invocation of the extended period under section 28(4). Differential duty and equal penalty under section 114A were sustained, but separate penalties under section 114AA were set aside.
Forensic extraction from a director's mobile phone was treated as admissible without a separate section 138C certificate because the phone was recovered under panchnama and examined in context with the surrounding record. Rule 12 permitted rejection of declared transaction value where reasonable doubt arose from the director's statement and parallel invoices showing higher values, so re-determination of assessable value was upheld. Misdeclaration of value attracted confiscation under section 111(m), and the same undisclosed invoices justified invocation of the extended period under section 28(4). Differential duty and equal penalty under section 114A were sustained, but separate penalties under section 114AA were set aside.
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