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...
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Gross profit additions on matched purchase-and-sale accommodation entries are unwarranted where the transaction profit has already been recorded and offered to tax. Estimating further profit solely from the purchase side is unsupported when books of account remain unrejected and quantitative records show no discrepancy. A gross profit rate derived from manufacturing activity cannot be applied to trading or accommodation transactions, because manufacturing margins reflect processing, labour and overheads not present in trading. In the absence of evidence of undisclosed procurement or genuine sales supported by unaccounted purchases, no further gross profit estimation is sustainable.
Gross profit additions on matched purchase-and-sale accommodation entries are unwarranted where the transaction profit has already been recorded and offered to tax. Estimating further profit solely from the purchase side is unsupported when books of account remain unrejected and quantitative records show no discrepancy. A gross profit rate derived from manufacturing activity cannot be applied to trading or accommodation transactions, because manufacturing margins reflect processing, labour and overheads not present in trading. In the absence of evidence of undisclosed procurement or genuine sales supported by unaccounted purchases, no further gross profit estimation is sustainable.
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