Tax deduction compliance and payee income recognition govern consultancy disallowance, while no exempt income prevents related expenditure disallowanc...
Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
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Rejection of audited books under section 145(3) requires specific defects in the accounts and cannot rest solely on non-compliance with sample third-party notices issued under section 133(6). Where the Assessing Officer verified the supplied particulars and the receipts of an HR outsourcing provider substantially comprised salary and statutory reimbursements as pass-through costs, treating total gross receipts as income and applying a fixed profit rate lacked a rational basis. The estimated addition was therefore arbitrary; deletion by the Commissioner (Appeals) was sustained and the Revenue's appeal was dismissed.
Rejection of audited books under section 145(3) requires specific defects in the accounts and cannot rest solely on non-compliance with sample third-party notices issued under section 133(6). Where the Assessing Officer verified the supplied particulars and the receipts of an HR outsourcing provider substantially comprised salary and statutory reimbursements as pass-through costs, treating total gross receipts as income and applying a fixed profit rate lacked a rational basis. The estimated addition was therefore arbitrary; deletion by the Commissioner (Appeals) was sustained and the Revenue's appeal was dismissed.
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