Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Reassessment beyond three years required the recorded reasons to show that the alleged escaped income was represented by an asset, expenditure, or entry in the books; absent that jurisdictional nexus, the notices and reassessment orders for AYs 2017-18 to 2019-20 were quashed. Material brought by a third person in response to summons during search could not be treated as search-seizure material to sustain notices under the search deeming fiction, so those notices were also invalid. The Tribunal further held that search information must relate to the relevant AY, and the absence of that link vitiated the notices for AYs 2020-21 to 2022-23. On merits, the wholesale two-zeroes theory on all cash entries was rejected, but 16% profit on recomputed unaccounted receipts was sustained.
Reassessment beyond three years required the recorded reasons to show that the alleged escaped income was represented by an asset, expenditure, or entry in the books; absent that jurisdictional nexus, the notices and reassessment orders for AYs 2017-18 to 2019-20 were quashed. Material brought by a third person in response to summons during search could not be treated as search-seizure material to sustain notices under the search deeming fiction, so those notices were also invalid. The Tribunal further held that search information must relate to the relevant AY, and the absence of that link vitiated the notices for AYs 2020-21 to 2022-23. On merits, the wholesale two-zeroes theory on all cash entries was rejected, but 16% profit on recomputed unaccounted receipts was sustained.
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