Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Disciplinary proportionality requires penalties for Authorised Representative misconduct to match proven harm, leading to reconsideration of registrat...
Reassessment founded on misstated facts, mechanically adopted investigation inputs, and transactions already examined in scrutiny constitutes an impermissible change of opinion and is invalid. Section 69A does not apply to recorded equity-share purchases where contract notes, broker records, and bank evidence establish the source of investment. It also cannot treat accounted sale proceeds of recorded shares as unexplained investment; taxing those proceeds again after the related income has been offered results in double taxation. Failure to verify supporting material or permit cross-examination of a retracted third-party statement further undermines the addition.
Reassessment founded on misstated facts, mechanically adopted investigation inputs, and transactions already examined in scrutiny constitutes an impermissible change of opinion and is invalid. Section 69A does not apply to recorded equity-share purchases where contract notes, broker records, and bank evidence establish the source of investment. It also cannot treat accounted sale proceeds of recorded shares as unexplained investment; taxing those proceeds again after the related income has been offered results in double taxation. Failure to verify supporting material or permit cross-examination of a retracted third-party statement further undermines the addition.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
