Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
The Tribunal held that sales to the assessee's partnership firm were genuine because the alleged bogus-sales finding rested only on third-party statements, while GST returns, Form 26AS, ledger accounts and bank evidence consistently supported the transactions. It noted that corresponding purchases were accepted, stock reduced on sale, and no defect was found in the documentary records or any incriminating material in search. In the absence of material showing the transactions were sham, the Revenue could not estimate commission or profit at 8% on assumptions and conjecture. The addition based on alleged bogus sales was deleted and the appeal was partly allowed.
The Tribunal held that sales to the assessee's partnership firm were genuine because the alleged bogus-sales finding rested only on third-party statements, while GST returns, Form 26AS, ledger accounts and bank evidence consistently supported the transactions. It noted that corresponding purchases were accepted, stock reduced on sale, and no defect was found in the documentary records or any incriminating material in search. In the absence of material showing the transactions were sham, the Revenue could not estimate commission or profit at 8% on assumptions and conjecture. The addition based on alleged bogus sales was deleted and the appeal was partly allowed.
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