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...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
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Commission expenditure supported by the recipient's tax and GST records, TDS details and bank-payment evidence cannot be disallowed solely because the recipient does not comply with a departmental notice, absent proof that the evidence is false, the identity is fictitious or funds returned to the payer. Primary evidence of a creditor's identity, creditworthiness and transaction genuineness shifts the burden to the Revenue; unsupported cash-credit additions fail. Business expenditure for customary lorry tips and refreshments may be allowable where commercially plausible, books are not rejected and no payment is shown to be bogus, inflated or non-business, despite absence of formal vouchers.
Commission expenditure supported by the recipient's tax and GST records, TDS details and bank-payment evidence cannot be disallowed solely because the recipient does not comply with a departmental notice, absent proof that the evidence is false, the identity is fictitious or funds returned to the payer. Primary evidence of a creditor's identity, creditworthiness and transaction genuineness shifts the burden to the Revenue; unsupported cash-credit additions fail. Business expenditure for customary lorry tips and refreshments may be allowable where commercially plausible, books are not rejected and no payment is shown to be bogus, inflated or non-business, despite absence of formal vouchers.
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