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...
Independent corroboration and a direct nexus with the assessee are presented as essential before search statements, loose papers or third-party records can support additions. The material discusses acceptance of documented consultancy expenditure where agreements, invoices, banking payments and tax deduction support services, while retracted statements and uncorroborated papers do not establish non-genuine expenditure. It also addresses alleged unaccounted sales, cash salaries, land on-money, unexplained money, and liaisoning or gift expenditure. For unexplained expenditure, actual incurrence must be proved before examining its source; estimates, ambiguous loose sheets, and uninvestigated retractions are insufficient. Third-party parallel records or off-portal order communications require evidence of unrecorded supply, cash receipt, dispatch, stock discrepancy, or other linkage to the assessee.
Independent corroboration and a direct nexus with the assessee are presented as essential before search statements, loose papers or third-party records can support additions. The material discusses acceptance of documented consultancy expenditure where agreements, invoices, banking payments and tax deduction support services, while retracted statements and uncorroborated papers do not establish non-genuine expenditure. It also addresses alleged unaccounted sales, cash salaries, land on-money, unexplained money, and liaisoning or gift expenditure. For unexplained expenditure, actual incurrence must be proved before examining its source; estimates, ambiguous loose sheets, and uninvestigated retractions are insufficient. Third-party parallel records or off-portal order communications require evidence of unrecorded supply, cash receipt, dispatch, stock discrepancy, or other linkage to the assessee.
Note: It is a system-generated summary and is for quick reference only.