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...
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.
Note: It is a system-generated summary and is for quick reference only.