https://www.taxtmi.com/caselaws?id=800409 Capital-gains treatment applied to share and securities sales where consistent investment treatment, deployment of non-interest-bearing surplus funds, absence of trading activity, and investment intent outweighed transaction volume. Payments for imported materials purchased from a non-resident parent did not attract withholding tax where they were not chargeable to tax in India; disallowance for non-deduction was consequently unavailable. An additional administrative-expense disallowance relating to exempt income could not be made through the prescribed formula without examination of the accounts and recorded dissatisfaction with the taxpayer's voluntary disallowance. The recharacterisation, purchase-payment, and incremental exempt-income disallowances did not survive. en-us Wed, 30 Sep 2026 00:00:00 +0530 Tue, 06 Oct 2026 08:13:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800409 Capital-gains treatment applied to share and securities sales where consistent investment treatment, deployment of non-interest-bearing surplus funds, absence of trading activity, and investment intent outweighed transaction volume. Payments for imported materials purchased from a non-resident parent did not attract withholding tax where they were not chargeable to tax in India; disallowance for non-deduction was consequently unavailable. An additional administrative-expense disallowance relating to exempt income could not be made through the prescribed formula without examination of the accounts and recorded dissatisfaction with the taxpayer's voluntary disallowance. The recharacterisation, purchase-payment, and incremental exempt-income disallowances did not survive. Case-Laws Income Tax Wed, 30 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800409