Separate speaking orders on reopening objections are mandatory; deciding them within reassessment invalidates jurisdiction and precludes revival of st...
Compulsorily convertible debentures remain debt before conversion, preventing transfer-pricing and interest-deduction disallowances on the stated fact...
Stock-in-trade transfer taxability follows possession and consideration, not later conveyance registration, limiting deemed-value provisions to the ac...
BSE futures and options trade profits disclosed for tax were supported by contract notes, tax records, bank statements, annual reports, transaction statements and account confirmations. Treating those profits as unexplained cash credit requires material showing that the broker or counterparty was tainted; no such material was identified. The preponderance-of-probabilities assessment distinguished alleged pre-arranged reversal trades involving loss-making entities from profitable trades with no identified loss-making counterparty. The trades were accepted as genuine, resulting in deletion of the unexplained cash credit addition and the consequential alleged commission expenditure addition under Section 69C.
BSE futures and options trade profits disclosed for tax were supported by contract notes, tax records, bank statements, annual reports, transaction statements and account confirmations. Treating those profits as unexplained cash credit requires material showing that the broker or counterparty was tainted; no such material was identified. The preponderance-of-probabilities assessment distinguished alleged pre-arranged reversal trades involving loss-making entities from profitable trades with no identified loss-making counterparty. The trades were accepted as genuine, resulting in deletion of the unexplained cash credit addition and the consequential alleged commission expenditure addition under Section 69C.
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