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...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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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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