Income Declaration Scheme declarations can evidence share-capital sources, while round-tripped funds and cash-linked credits require further verificat...
Permanent establishment tests: independent subsidiary premises and principal-to-principal dealings did not create Indian taxability for offshore suppl...
Valuation Officer estimates govern property-value additions once statutory valuation is invoked, requiring fresh consideration of objections and compa...
Waiver of written show-cause notice may prevent a later procedural challenge after participation in customs adjudication, preserving statutory appella...
Retrospective invalidity of ocean-freight IGST supports refunds despite non-party status and prior credit utilisation, subject to authorised appeal gr...
Additional evidence in departmental appeals may include show-cause-notice material without introducing a new case where it merely corroborates existin...
Reasoned rectification orders require consideration of expenditure disclosed in income-tax returns, preventing revision based on incomplete income com...
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Cash gifts from close relatives cannot be treated as unexplained credits where gift deeds, confirmations, tax returns, financial statements and responses to statutory notices establish donor identity, transaction genuineness and basic creditworthiness. The assessee's initial burden is then discharged, and any enquiry into donors' actual funding sources belongs in their own assessments unless a statute provides otherwise. Earlier adverse donor assessments or doubts about financial capacity cannot alone establish that gifted funds were the assessee's own money. On these principles, the cash-gift addition and consequential special-rate tax treatment were deleted.
Cash gifts from close relatives cannot be treated as unexplained credits where gift deeds, confirmations, tax returns, financial statements and responses to statutory notices establish donor identity, transaction genuineness and basic creditworthiness. The assessee's initial burden is then discharged, and any enquiry into donors' actual funding sources belongs in their own assessments unless a statute provides otherwise. Earlier adverse donor assessments or doubts about financial capacity cannot alone establish that gifted funds were the assessee's own money. On these principles, the cash-gift addition and consequential special-rate tax treatment were deleted.
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