Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Estimated stock additions based on sample weighment and incomplete books were deleted where no scientific basis for the stock working was shown and the assessee's reconciliation went unrebutted. WhatsApp chats and section 132(4) statements supported some suppression of production, but extrapolation to the whole year was rejected; only 10% profit on the limited-period difference was sustained. Long-outstanding sundry creditors did not attract section 41(1) absent evidence of remission or benefit. For completed years, additions under section 153A required incriminating search material, so extrapolation alone could not support the earlier years. Unsecured loans were accepted where identity, creditworthiness, genuineness, banking trail and repayment were proved. A third-party Tally ledger, without linkage to the assessee's own records, could not sustain an unexplained investment addition.
Estimated stock additions based on sample weighment and incomplete books were deleted where no scientific basis for the stock working was shown and the assessee's reconciliation went unrebutted. WhatsApp chats and section 132(4) statements supported some suppression of production, but extrapolation to the whole year was rejected; only 10% profit on the limited-period difference was sustained. Long-outstanding sundry creditors did not attract section 41(1) absent evidence of remission or benefit. For completed years, additions under section 153A required incriminating search material, so extrapolation alone could not support the earlier years. Unsecured loans were accepted where identity, creditworthiness, genuineness, banking trail and repayment were proved. A third-party Tally ledger, without linkage to the assessee's own records, could not sustain an unexplained investment addition.
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