Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Bogus purchases from accommodation entry providers were not disallowed in full where the assessee's sales were undisputed and it had maintained quantitative details, stock records, purchase and sales registers, and banking trail. The Tribunal noted that the suppliers were found non-genuine in investigation, but the record did not support an inference that no purchases had been made at all. In such circumstances, only the profit element embedded in the alleged bogus purchases could be taxed, on the footing that goods may have been sourced from the grey market and bills obtained from named parties. The disallowance was therefore restricted to 10% and the balance addition was deleted.
Bogus purchases from accommodation entry providers were not disallowed in full where the assessee's sales were undisputed and it had maintained quantitative details, stock records, purchase and sales registers, and banking trail. The Tribunal noted that the suppliers were found non-genuine in investigation, but the record did not support an inference that no purchases had been made at all. In such circumstances, only the profit element embedded in the alleged bogus purchases could be taxed, on the footing that goods may have been sourced from the grey market and bills obtained from named parties. The disallowance was therefore restricted to 10% and the balance addition was deleted.
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