Appellant booked artificial short-term capital loss by ...
Fraudulent tax evasion through sham transactions, artificial losses; exorbitant rates to group entities, interest disallowance on exempt income.
October 4, 2024
Case Laws Income Tax AT
Appellant booked artificial short-term capital loss by purchasing shares from group entities at exorbitant rates and selling same shares to other group entities at lower rates to offset huge capital gains. Transaction lacked genuineness, designed solely to avoid taxes. Cost of purchase rightly recomputed by authorities at Rs.33 per share. Interest expenditure disallowed u/s 14A as appellant failed to substantiate investments were for strategic business purposes, admitted using interest-bearing funds for non-business investments yielding exempt income. CIT(A)'s order upheld, assessee's appeal dismissed by Appellate Tribunal.
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