https://www.taxtmi.com/article/detailed?id=1753 A footnote appended to a taxpayer's return cannot determine whether a receipt is taxable as a capital gain; statutory taxability depends on substantive law and evidential material. The assessee's notation that amounts were transferred to capital reserve did not, without supporting facts or legal analysis, prevent the assessing and appellate authorities from treating the declared sum as capital gain. Absent production of material to rebut taxability, appellate bodies may reject a contention based solely on a footnote. en-us Fri, 01 Jun 2012 10:34:37 +0530 Fri, 01 Jun 2012 10:34:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/article/detailed?id=1753 A footnote appended to a taxpayer's return cannot determine whether a receipt is taxable as a capital gain; statutory taxability depends on substantive law and evidential material. The assessee's notation that amounts were transferred to capital reserve did not, without supporting facts or legal analysis, prevent the assessing and appellate authorities from treating the declared sum as capital gain. Absent production of material to rebut taxability, appellate bodies may reject a contention based solely on a footnote. Articles Income Tax Fri, 01 Jun 2012 10:34:37 +0530 https://www.taxtmi.com/article/detailed?id=1753