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...
Cash returned by builders from property payments made through banking channels constitutes circulation of explained funds, not unexplained money, unless evidence establishes a separate unexplained asset or accretion; the related addition was deleted. Alleged cash interest from builder financing was unsustainable where disclosed property investments, rent and capital gains supported appreciation rather than separate interest; that addition was deleted. Acquisition below stamp-duty value can attract section 56(2)(x)(b) irrespective of a transaction's builder-financing character, but disputed values require fair-market-value determination before taxability is decided; the issue was remanded. Set-off of brought-forward long-term capital loss was also remanded for verification of eligibility and the character of current-year capital gains.
Cash returned by builders from property payments made through banking channels constitutes circulation of explained funds, not unexplained money, unless evidence establishes a separate unexplained asset or accretion; the related addition was deleted. Alleged cash interest from builder financing was unsustainable where disclosed property investments, rent and capital gains supported appreciation rather than separate interest; that addition was deleted. Acquisition below stamp-duty value can attract section 56(2)(x)(b) irrespective of a transaction's builder-financing character, but disputed values require fair-market-value determination before taxability is decided; the issue was remanded. Set-off of brought-forward long-term capital loss was also remanded for verification of eligibility and the character of current-year capital gains.
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