https://www.taxtmi.com/caselaws?id=801319 Post-transfer receipts reflected in Form 26AS are not conclusively taxable to the PAN holder where substantive material shows that the underlying business and revenue transferred to a successor entity. Verification is required to confirm that the successor accounted for and was taxed on the receipts, and that the original entity did not claim the related TDS credit; verified duplicate taxation requires deletion of the addition and appropriate regulation of TDS credit. Advertising expenditure is deductible when invoices, publication evidence, payment records and TDS establish actual promotional services and business nexus. Related-party status, absent separate agreements, and no immediate revenue increase do not alone justify disallowance without proof of excessiveness. en-us Mon, 31 Aug 2026 00:00:00 +0530 Mon, 19 Oct 2026 07:01:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=801319 Post-transfer receipts reflected in Form 26AS are not conclusively taxable to the PAN holder where substantive material shows that the underlying business and revenue transferred to a successor entity. Verification is required to confirm that the successor accounted for and was taxed on the receipts, and that the original entity did not claim the related TDS credit; verified duplicate taxation requires deletion of the addition and appropriate regulation of TDS credit. Advertising expenditure is deductible when invoices, publication evidence, payment records and TDS establish actual promotional services and business nexus. Related-party status, absent separate agreements, and no immediate revenue increase do not alone justify disallowance without proof of excessiveness. Case-Laws Income Tax Mon, 31 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=801319