Reasoned rectification orders require consideration of expenditure disclosed in income-tax returns, preventing revision based on incomplete income com...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
Cash-method accounting precludes taxation of notional interest,...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and verification.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
Cash-method accounting precludes taxation of notional interest, dividend or interest income unless actual receipt is established; rejection of books does not by itself justify mercantile or presumptive assessment. Ready-forward securities transactions are treated in substance as short-term lending and do not necessarily generate share-trading profit. Negative opening stock, undelivered securities transactions, brokered trades and prior-year advances cannot be treated as unexplained investment for the relevant year without supporting material. Unexplained bank credits remain taxable where their nature and source are not satisfactorily explained. Appellate enhancement requires opportunity, while disclosed-source claims may require verification. Telescoping against assessed income, statutory deductions and tax credit require consequential application; interest on a fresh demand after de novo assessment runs from default under that fresh demand.
Cash-method accounting precludes taxation of notional interest, dividend or interest income unless actual receipt is established; rejection of books does not by itself justify mercantile or presumptive assessment. Ready-forward securities transactions are treated in substance as short-term lending and do not necessarily generate share-trading profit. Negative opening stock, undelivered securities transactions, brokered trades and prior-year advances cannot be treated as unexplained investment for the relevant year without supporting material. Unexplained bank credits remain taxable where their nature and source are not satisfactorily explained. Appellate enhancement requires opportunity, while disclosed-source claims may require verification. Telescoping against assessed income, statutory deductions and tax credit require consequential application; interest on a fresh demand after de novo assessment runs from default under that fresh demand.
Note: It is a system-generated summary and is for quick reference only.