Departmental appeal limitation after call-book recall preserves original filing, while documented correlation supports SAD refund on imported granules...
Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from...
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Brought-forward capital cannot be assessed as current-year income merely because an originally reported balance-sheet figure is erroneous; a demonstrable accounting correction supported by accepted prior-year records is permissible absent evidence of fresh unexplained accretion. Alleged on-money for immovable property requires cogent proof of actual payment, and a retracted vendor statement or unconnected cash deposits does not establish ownership of unexplained money. Section 68 requires a credit arising in the relevant year, so aggregate closing creditor balances, internal appropriations, prior-year liabilities and supported chit liabilities cannot be taxed without component-wise examination. Recorded sundry debtors are debit receivables, not cash credits or unrecorded investments. On these principles, the four additions were deleted.
Brought-forward capital cannot be assessed as current-year income merely because an originally reported balance-sheet figure is erroneous; a demonstrable accounting correction supported by accepted prior-year records is permissible absent evidence of fresh unexplained accretion. Alleged on-money for immovable property requires cogent proof of actual payment, and a retracted vendor statement or unconnected cash deposits does not establish ownership of unexplained money. Section 68 requires a credit arising in the relevant year, so aggregate closing creditor balances, internal appropriations, prior-year liabilities and supported chit liabilities cannot be taxed without component-wise examination. Recorded sundry debtors are debit receivables, not cash credits or unrecorded investments. On these principles, the four additions were deleted.
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