Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Project Falcon material, standing alone, could not justify an addition under section 68 where the assessee had already recorded the option-trading profit in its profit and loss account, the trade data showed both gains and losses, and there was no direct assessee-specific evidence of a manipulative reversal-trade arrangement. The Tribunal held that the proposed addition would also amount to double taxation, so the deletion of the section 68 addition and the related commission disallowance under section 69C was upheld. On the alleged accommodation loan, the assessee discharged the burden by producing cheque payment, books, confirmations, bank statements and repayment evidence, while the lender's financials showed creditworthiness; in the absence of contrary inquiry or direct linkage, the section 68 addition was unsustainable and its deletion was affirmed.
Project Falcon material, standing alone, could not justify an addition under section 68 where the assessee had already recorded the option-trading profit in its profit and loss account, the trade data showed both gains and losses, and there was no direct assessee-specific evidence of a manipulative reversal-trade arrangement. The Tribunal held that the proposed addition would also amount to double taxation, so the deletion of the section 68 addition and the related commission disallowance under section 69C was upheld. On the alleged accommodation loan, the assessee discharged the burden by producing cheque payment, books, confirmations, bank statements and repayment evidence, while the lender's financials showed creditworthiness; in the absence of contrary inquiry or direct linkage, the section 68 addition was unsustainable and its deletion was affirmed.
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